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Motion For Extension of Time To File Counter Affidavit

The respondents are requesting a 10 day extension to submit their counter-affidavits and supporting documents in response to charges of robbery with homicide and robbery with frustrated homicide. They state they had difficulty obtaining legal counsel and need more time to study the case and gather evidence to prove their innocence. They assure the court this request is not to delay proceedings but due to the reasons provided.

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90% found this document useful (10 votes)
12K views2 pages

Motion For Extension of Time To File Counter Affidavit

The respondents are requesting a 10 day extension to submit their counter-affidavits and supporting documents in response to charges of robbery with homicide and robbery with frustrated homicide. They state they had difficulty obtaining legal counsel and need more time to study the case and gather evidence to prove their innocence. They assure the court this request is not to delay proceedings but due to the reasons provided.

Uploaded by

Bibo Gunther
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
CITY PROSECUTOR’S OFFICE
Calbayog City

MERIAM FRANCISCO y NPS Docket No. VIII-10-


WENCESLAO, INV-19F-00091
Complainant,
- For –
- Versus -
ROBBERY WITH
RONEL RUBANTE @ Onel, HOMICIDE and ROBBERY
Alias BING BING PANZUELO, WITH FRUSTRATED
JOSE TANEO @ Osik, HOMICIDE
JOJO DELIQUIÑA,
NOEL PANZUELO @ Bota,
Respondents.

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

JOINT MOTION FOR EXTENSION OF TIME


TO SUBMIT COUTER AFFIDAVIT

The Respondents, unto the Honorable City Prosecutor, most


respectfully state:

1. On July 09, 2019, we received a subpoena from the City Prosecutor’s


Office charging us of the above-stated offense and requiring us to
submit our counter-affidavits and other supporting documents within
Ten (10) days from receipt thereof;

2. That on account of our difficulty to engage the services of a counsel,


we prayed before this Honorable City Prosecutor for an extension of
time to file counter affidavit, which we submitted last July 18, 2019;

3. The nature of the offense charged against us is of a crime of utmost


gravity;

4. And we are in dire need to further study the case and to gather
relevant evidence to support our defense and prove our innocence,
thus, this request for a period of another Ten (10) day extension within
which to submit the our Counter-Affidavits and other supporting
documents;

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

PRAYER

WHEREFORE, premises considered, we, the Respondents, in the


interest of justice and equity, respectfully prays before the Honorable City
Prosecutor that we be given an additional period of TEN (10) DAYS from
receipt hereof within which to submit our Counter-Affidavits and other
supporting documents.

Calbayog City, Samar, Philippines, July 29, 2019.

RONIL RUBANTE JOSE TANEO


Respondent Respondent

AMADO ‘Bing Bing” PANZUELO


Respondent

Copy Furnished:

Meriam Francisco y Wenceslao


Brgy. Tingolon
Isabel, Leyte

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