Republic of the Philippines

OFFICE OF THE CITY PROSECUTOR

Caloocan City

JOEL M. MOMOA
Complainant,

-versus- XV-02-INV-19D-01226

DONNA M. DIAZ
Respondents.
x-----------------------------------------x

MOTION TO ADMIT
COUNTER-AFFIDAVIT

Respondent DONNA M. DIAZ, by counsel, respectfully states:

1. On July 23, 2019, respondent filed her Motion to Re-open

Preliminary Investigation praying that she be given the opportunity
to submit her counter-affidavit because she received the subpoena
only after the hearing dates.

2. Respondent has not received an order or resolution on

her Motion to Re-open.

3. Respondent submits her Counter-Affidavit to form part

of her Motion to Re-open and undertakes to personally appear
should the investigating prosecutor require her to take an oath before
him.

WHEREFORE, respondent respectfully reiterates her prayer for

the REOPENING of the preliminary investigation and the
ADMISSION of her attached Counter-Affidavit.

Other reliefs, just and equitable under the premises, are

likewise prayed for.

[EXPLANATION FOR THE MODE OF SERVICE: Service will be

done by registered mail due to the shortage of office personnel who can
undertake personal service.]

Pasig City, September ___, 2019.