Republic of the Philippines

Department of Justice
Office of the Prosecutor
QUEZON CITY

RAYMUNDO C. REYES,
Complainant/s,

- versus - XV-03-INV-20L-05213
FOR: ESTAFA

DIMPLES ESTRELLA
JUSTIN MARCUS KOA
ORLANDO BUCACAO
Respondent/s.

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ENTRY OF APPEARANCE WITH MOTION FOR TIME TO FILE

RESPONDENTS’ COUNTER-AFFIDAVIT

The undersigned counsel respectfully enters their appearance

in behalf of Respondents Dimples Estrella, Justin Marcus Koa, and
Orlando Bucacao (hereinafter referred to as “Respondents”) with a
request that all notices, orders, and other processes of the Office of
the Prosecutor (“Honorable Office”) shall henceforth be forwarded to
their address stated below, and state:

1. Respondents received a Subpoena dated 14 January

2021 from this Honorable Office commanding and requiring the
respondent/s to appear and submit a sworn Counter-Affidavit/s.
However, it is most respectfully manifested that the above case was
unfortunately just endorsed to the undersigned counsel. The lawyer
originally handling this case is currently on leave. In addition to that,
the undersigned law firm was recently notified of the said Subpoena
last 11 February 2021, Thursday.

2. Nevertheless, it is respectfully manifested that the

undersigned counsel already started reviewing the case and drafting
the Counter-Affidavit/s for the Respondents but due to time
constraints, incomplete documents plus heavy volume of work, which
consists of drafting other pleadings in other equally important cases
being handled, attendance at hearings, numerous meeting with
clients and preparation of various legal documents, and conflict in
schedule, she was unable to finalize the Counter-Affidavit.

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 3. Thus, the undersigned counsel respectfully requests the
Honorable Office to grant an extension of fifteen (15) days from 16
February 2021 or until 03 March 2021 to file their respective sworn
Counter-Affidavits.

4. This Motion is not intended to delay the proceedings in

this case but is solely necessitated for the reasons stated above.

PRAYER

WHEREFORE, it is respectfully prayed that the Honorable

Senior Assistant City Prosecutor grant the Respondents an extension
of fifteen (15) days from 16 February 2021 or until 03 March 2021
within which to file the Respondents’ sworn Counter-Affidavit.

Other just and equitable reliefs are likewise prayed for.

Taguig City for the Quezon City, 15 February 2021.

BATUHAN BLANDO CONCEPCION & TRILLANA

Counsel for Defendant
th
15 Floor, Picadilly Star Building,
4th Ave., cor 27th Street
Bonifacio Global City, Taguig City
Telephone Number:  846-8004
Email Address:  bbctlaw@bbclawoffice.net

By:

MIKEE ANGELU S. PORTES

PTR No. A-4962463; 22 September 2021; Taguig City
IBP No. 127428; 17 August 2020; Quezon Chapter
Roll of Attorneys No. 74929
MCLE Compliance No.: N/A (Admitted to the Bar July 2020)

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 NOTICE OF HEARING

Greetings:

Please be informed that the undersigned counsel is submitting

the foregoing Motion for the immediate consideration and approval of
this Honorable Office.

MIKEE ANGELU S. PORTES