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Sample motion for extension.
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Republic of the PhilippinesDepartment of Justice
OFFICE OF THE CITY PROVINCIAL PROSECUTORCapitol, Cebu City
PNP SAN FERNANDO CEBU,Complainant,
NPS Docket No. 03-INQ-15H-1254
-vs- For: Qualified Trafficking(Sec. 4, par. A of RA 10364)
DANIEL ALAN NIELSEN,Respondent.
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MOTION FOR EXTENSION OF TIME
RESPONDENT, by the undersigned counsels, and unto this Honorable Office, most respectfully states that:
1. Respondent engaged the services of the undersigned counsels after he was arrested without warrant for violation of Sec. 4, par. A of R.A 10364 on August 04,2015 ;
2. Respondent refused to undergo an inquest proceeding and requested for a preliminary investigation ;
3. Respondent was given five (5) days within which to file his counter-affidavit and other supporting evidence which five days commence to run on August 06, 2015, hence, the fifth day reglementary period is due on August 10,2015 ;
4. However, due to the pressures of equally urgent professional work and prior commitments and time constraints by reason of holiday on August 6, Cebu Provincial Charter Day and non-working days on August 8 and 9 (Saturday and Sunday) the undersigned counsels will not be able to meet the said deadline;
5. As such, undersigned counsel is constrained to request for an additional period of five (5) days from today within which to submit
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Respondents counter-affidavit and supporting evidence. Moreover, this additional time will also allow the undersigned to interview the available witness and study this case further;
5. This motion is not intended for delay but solely due to the foregoing reasons.
P R A Y E R
WHEREFORE, Respondent most respectfully prays of this Honorable Office that he be given an additional period of FIVE (5) days from today within which to submit counter-affidavits and other supporting evidences.
Other relief just and equitable are likewise prayed for.
Cebu City, Philippines, August 10, 2015.
RESPECTFULLY SUBMITTED.
LOON CORPUZ PATIÑO AND ASSOCIATES(Counsel of the Accused)
G/F GMC Plaza Bldg. Legaspi Extensioncorner M.J Cuenco St, Cebu City, Philippines
Tel No. (032) 254-0453
By:
JURIL B. PATIÑORoll of Attorney No. 63966 April 27,2015
PTR OR No. 707854 5-06-15IBP OR No. 0997508 4-27-15 Cebu City ChapterMCLE COMPLIANCE No. Exempt-New Passer
Email add: [email protected]
HABEAS CORPUZRoll of Attorney No. 62850 May 06,2014
PTR OR No. 599058 January 07,2015 Cebu CityIBP OR No. 966627 January 7,2015 Cebu City Chapter
MCLE COMPLIANCE No. Exempt-New PasserEmail add: [email protected]
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