REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR OF CAVITE
HALL OF JUSTICE Compound, Aguinaldo highway
Imus, Cavite

LUISITO BINAS,
Complainant,

- versus - NPS Docket No. IV-03-INV-21K-

4791
FOR : SYNDICATED ESTAFA
KIRK EDUARDO ROSAL
ANNIE CHAVEZ
ROMMEL DELA CRUZ
Respondents.
X ------------------------------------------ X

MOTION FOR EXTENSION OF TIME

TO SUBMIT COUNTER- AFFIDAVIT
WITH ALL DUE RESPECT, Respondent unto this Honorable Office

most respectfully states THAT:

1. The above-captioned case was set for preliminary

investigation and to submit their respective counter on January 6

& 13, 2022 at 2:00 o’clock in the afternoon.;

2. Respondents (CHAVEZ & DELA CRUZ)were only

informed that there was a case filed against them when co-

respondent ROSAL received a subpoena from this Honorable office;

3. On January 3, 2022, the Government put NCR and its

nearby provinces including Cavite on Alert Level 3 due to omicron

virus surge, respondent were having a hard time to look for a

lawyer of their own choice to represent them before this Honorable

office and to submit their counter-affidavit and physical evidences

to prove their innocence of the offense charged aside from the fact
that all of the respondents reside from the North that gave them

limited movements to look for private lawyer of their own choice;

3. Hence, the respondents respectfully moving for an

additional period of ten (10) days within which to secure the

services of counsel to assist them in the preparation of their

respective counter-affidavit and much needed physical evidences;

4. That this motion is not intended to delay the resolution

this case but only for reason above-stated.

WHERFORE, premises considered, it is most respectfully

prayed to this Honorable office that the respondents be given an

extension of TEN (10) days within which to file their counter-

affidavit to prove their innocence of the offense charged.

San Fernando, Pampanga for Imus, Cavite January 11, 2022.

ROMMEL DELA CRUZ

Respondent

NOTICE OF HEARING

THE CLERK
Office of the Provincial Prosecutor
Imus, Cavite

Greetings:

Kindly submit the foregoing motion for the consideration and

approval of the Honorable Provincial Prosecutor immediately upon

receipt hereof.
 ROMMEL DELA CRUZ

COPY FURNISHED

LUISITO BINAS
Blk. 19, Lot12, Jordan Estate Subdn.,
San Jose 2, Noveleta, Cavite 4105