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XI MOTIONS
E. EXTENSION OF TIME
Form No. 2--Motion
for Extension of Time to Submit Counter Affidavit
(Motion
for Extension of Time to Submit Counter Affidavit)
(CAPTION)
MOTION FOR EXTENSION OF TIME
Respondent, by the
undersigned counsel, and unto this Honorable Office of the City
Prosecutor, most respectfully states that:
1.
Respondent engaged the services of
undersigned counsel only on _____________;
2.
Respondent received the subpoena on
_____________ and thus has until
_____________ within which to submit
his counter-affidavit;
3.
However, due to the pressures of equally
urgent professional work and prior commitments, the undersigned
counsel will not be able to meet the said deadline;
4.
As such, undersigned counsel is
constrained to request for an additional period of
_____________ from today within
which to submit Respondent's counter-affidavit and other supporting
evidence. Moreover, this additional time will also allow the
undersigned to interview the available witness and study this case;
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 City Prosecutor of
_____________ that he be given an
additional period of _____________
from today within which to submit his counter-affidavit and other
documentary evidence.
MOST RESPECTFULLY SUBMITTED.
Other relief just and
equitable are likewise prayed for.
_____________,
Philippines, __Date__.
(COUNSEL)
(NOTICE OF HEARING)
(EXPLANATION)
COPY FURNISHED:
OPPOSING COUNSEL
Form No. 1--Motion
for Intervention
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