Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Tayug, Pangasinan

AAA,
Complainant,

-versus- 12345678
For: RA 7610 (Non-Support)

BBB
Respondent.

x-------------------------------------------------x

MOTION FOR EXTENSION OF TIME

TO FILE COUNTER-AFFIDAVIT

Respondent, BBB, assisted by Atty. CCC, unto this Honorable Provincial

Prosecutor, most respectfully avers that:
1. On November 14, 2022, respondent’s niece, XXX, received a subpoena from the
Prosecutor’s Office charging Respondent of the above-stated offense and
requiring him to submit his counter-affidavit and other supporting documents
within (ten) 10 days from receipt thereof;

2. The deadline to submit the counter-affidavit is on November 24, 2022;

3. The respondent is outside of the Philippines;

4. There is a need for the Respondent to procure an SPA with Apostille in order for
someone to represent and defend him in the instant case;

5. Thus, in the interest of substantial justice, the undersigned would like to ask for
sixty (60) days within which to procure the necessary SPA and to properly submit
his counter-affidavit and other supporting documents;

6. That filing this motion is done in good faith and not for purposes of delaying the
proceedings of this case but for the reason above-stated;

Nueva Ecija Philippines, Philippines, this 18th day of November 2022.

ATTY. CCC
Counsel for the Respondent
Roll of Attorney’s No. 12345
PTR No.NE 12345 Date, Place
IBP No. 654321; 5/12/2022; Pampanga Chapter
MCLE Governing Board Order No.1, S.2008
Mobile No.
Email:
Copy Furnished by
Registered Mail to:

Public Prosecutor YYY

The Clerk of the Provincial Prosecutor
Office of the Provincial Prosecutor
Tayug, Pangasinan

AAA
San Quintin, Pangasinan

REQUEST:

The Clerk of the Provincial Prosecutor

Justice Hall, Tayug, Pangasinan

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.

Atty. CCC
Counsel for the Respondent

EXPLANATION

Copies of the foregoing Motion for Extension of Time to File Counter-Affidavit

were served on the Affiants by registered mail since personal service is not practicable in
view of time constraint and the distance between the residence of the petitioner and the
Office of the Affiants.

Atty. CCC
Counsel for the Respondent