Form No. 2--Motion for Extension of Time to Submit Counter Affidavit

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(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