Republic of the Philippines

DEPARTMENT OF JUSTICE
Office of the City Prosecution
Davao City

PICULADOS NPS Docket No. 299

Complainant,

-versus-

CAN, ET. ALS. For: FALSIFICATION OF PUBLIC

Respondent, DOCUMENT

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URGENT MOTION FOR EXTENSION OF TIME TO FILE

COUNTER-AFFIDAVIT

NOW COME, the Respondents through the undersigned counsel, and

unto this Honorable Office respectfully state:

1. That on July 7, 2015, the respondents received a subpoena to file

their counter affidavit and other supporting documents;

2. The said subpoena required the respondents to submit the

counter-affidavit within ten (10) days from receipt or until Friday
July 17, 2015;

3. Since the said date falls on a recently declared Holiday, the

respondents have until Monday or July 20, 2015 to submit their
counter-affidavit according to the rules;

4. However, the respondents have engaged the services of the

undersigned counsel for their counter-affidavits only yesterday,
July 13, 2015;

5. The undersigned has yet to gather the individual statements of the

respondents and to gather all data and other evidences to support
theirjoint counter-affidavit;
 6. As the respondents are numerous, the undersigned cannot
effectively finish all the necessary works by the aforementioned
deadline;

7. The undersigned now pleads this Honorable Office to give an

additional period of fifteen (15) calendar days to file the said
counter- affidavit and other supporting documents and evidences
to be reckoned from the receipt of this motion;

8. That this motion is not intended to delay the proceedings but only
for the said reason;
PRAYER

WHEREFORE, premises considered, in the interest of justice, it is

respectfully prayed of this Honorable Office that an extension of fifteen (15)
days be given within which to file the respondents’ counter-affidavit.

Other reliefs, just and equitable under the circumstances, are likewise
prayed for.

Respectfully submitted.July 15, 2015, at Davao City, Philippines.

Assisted by:

By:

Copy Furnished:

PICULADOS
Davao City