REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
ILOILO CITY
xXx

Complainant
-versus- For:

Respondent

_______________________________oOo________________________________

MOTION FOR EXTENSION OF TIME TO FILE

COUNTER AFFIDAVIT

The respondent, unto this Honorable City Prosecutor and thru

herein Counsel, most respectfully prays that she be granted an extension of

ten (10) from June 6 2022, the ninth day of her ten days to file her counter-

affidavit and those of his witnesses having received the subpoena.

1. Respondent was notified of the subpoena last May 28, 2022 commanding

her to respond to the above stated accusation within ten (10) days from

receipt of the Subpoena. Respondent was at that time in Antique to attend to

some personal business;

2. Upon learning of the Subpoena, Respondent immediately contacted

various persons to secure documents and other necessary evidences which

will negate her liability. Unfortunately, some of these documentary

evidences have yet to be submitted to the Respondent;

3. Respondent was able to secure the services of Counsel to personally assist

her only last June 3, 2022 as evidenced by the signed Retainer Agreement

herein attached as Annex A;

4. Today appears to be the ninth day of the ten day period that was given for

the Respondent to submit a counter affidavit along with documents and

other affidavits of the Respondent’s witness to the Subpoena thus, this

request for a period of ten (10) days extension within which to submit a

Counter-Affidavit and other supporting documents;

5. That the filing of this Motion is made in good-faith and not done for

purposes of delaying the proceedings nor making a mockery of the processes

for this case but for the above reason herein stated.

PRAYER

WHEREFORE,premises considered,it is respectfully prayed of the

Honorable Prosecutor that this Motion,praying for an extension of TEN(10)

DAYS within which to submit Respondent’s Counter-Affidavit and

supporting documents, be granted.

Respectfully submitted

CONFORME:

____________________

NOTICE

The Clerk
Office the City Prosecutor
City of Iloilo

GREETINGS:
Please submit the foregoing motion for the consideration of the

Honorable City Prosecutor immediately upon receipt hereof without

further oral argument.

COPY FURNSHED:

Counsel of the Complainant

This Motion is not intended to delay the proceedings scheduled for

June 9, 2022.

SUBSCRIBED AND SWORN to before me, a Notary Public in and

for ______________________________, this _____ day of
_____________, 2022, at _______________________. Affiant
exhibited to me her _______________________________. I further
certify that I personally examined the affiant and I am satisfied that
she understood it and that he voluntarily executed the same.

Doc_____
Page_____
Book_____
Series____

Copy furnished by registered mail to:

Percival Peñalosa thru:

Counsel for the Complainant

Copy furnished by personal service to:

The Honorable City Prosecutor

REQUEST:

The Clerk of the City Prosecutor

Iloilo City Hall of Justice

Greetings:

Immediately upon receipt hereof, kindly submit the foregoing

Motion to the Honorable Provincial Prosecutor for his consideration,
approval and resolution, with or without complainant’s
comment/opposition thereto.

EXPLANATION OF SERVICE

Copies of the foregoing MOTION FOR EXTENTION OF

TIME TO FILE COUNTER-AFFIDAVIT was furnished to the
counsel of the complainant thru registered mail since personal service
was not practicable in view of the time constraint and distance
between residence of the Respondent and the Counsel of the
Complainant.