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Republic of the Philippines

REGIONAL TRIAL COURT


National Capital Region
Quezon City
Branch 18

JAMES LIBRON,
Petitioner,
Civil Case No.123456
For: Injunction
- Versus -

DWAYNE WAHE,
Respondent,

X----------------------------------------X

MOTION FOR EXTENSION OF TIME


Respondent, assisted by the Public Attorney’s Office (PAO), unto the
Honorable Court, most respectfully aver(s), that:

1. On 25 February 2019, Respondent received a subpoena from


the Prosecutor’s Office charging him of the above-stated offense and
requiring him to submit his counter-affidavit and other supporting
documents within (ten)10 days from receipt thereof from receipt thereof on
until 7 March 2019.

2. On 7 March 2019, on the last day of submitting the counter-


affidavit and other supporting documents was also the same day this case
was assigned to her, the undersigned counsel was scheduled to attend an off-
site meeting in Iloilo and only returned to the office on 12 March 2019;

3. There is a need for the undersigned counsel to gather relevant


evidence to support the defenses of the respondent;

4. However, due to pressures of equally urgent professional work


and prior commitments, the undersigned requests for a period of ten (10)
day extension within which to submit the counter-affidavit and other
supporting documents;

5. That the filing of this motion is done in good faith and not for
the purpose of delaying the case but for the reason above-stated.
MOTION FOR EXTENSION
Civil Case No.123456
For: Injunction x--------------------------------------------------x

6. Hence, it is with profuse apologies, the undersigned interposes


this motion in good faith and without intention of causing delay.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed that the
attached answer be admitted and considered in the resolution of his case.

Respondent also prays for other reliefs as may be deemed just and
equitable in the premises.

Quezon City, 19th March 2019

(sgd)
ATTY. MICHAELA THERESE A.
FLORES
State Solicitor/ Counsel for the Defendant
Unit 209 Page 1 Bldg. Quezon City
Roll No. 155427
IBP No. 22561
PTR No. 8712560
MCLE Compliance No. 0091269
Tel. Nos. 853-4322; 853-4355
Email Address:
michaelatherese.flores@gmail.com

Copy Furnished:

(sgd)
Atty. Denzel Wueta
Counsel for the Petitioner

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