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Motion For Extension To File Counter Affidavit

The respondent Teofisto R. Alcon, represented by the Public Attorney's Office, filed a motion for a 10-day extension to submit his counter-affidavit and supporting documents in response to charges of rape under Article 266 of the Revised Penal Code. Alcon received a subpoena on December 22, 2018 requiring documents be submitted within 10 days, making January 1, 2019 the deadline. However, more time is needed to study the case and gather evidence for Alcon's defense. The motion is filed in good faith and not to delay proceedings.

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Bleizel Teodosio
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1K views4 pages

Motion For Extension To File Counter Affidavit

The respondent Teofisto R. Alcon, represented by the Public Attorney's Office, filed a motion for a 10-day extension to submit his counter-affidavit and supporting documents in response to charges of rape under Article 266 of the Revised Penal Code. Alcon received a subpoena on December 22, 2018 requiring documents be submitted within 10 days, making January 1, 2019 the deadline. However, more time is needed to study the case and gather evidence for Alcon's defense. The motion is filed in good faith and not to delay proceedings.

Uploaded by

Bleizel Teodosio
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 PHILILPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
Tacloban City

MARIA JOSEFINA B. CRUZ, I.S. NO.


Complainant, FOR: RAPE UNDER ART. 266 OF
THE REVISED PENAL CODE (RPC)
-versus-

TEOFISTO R. ALCON,
Respondent(s).
x-------------------------------------------------x

MOTION FOR EXTENSION OF


TIME TO SUBMIT COUNTER-
AFFIDAVIT

Respondent, TEOFISTO R. ALCON, assisted by Public Attorney’s Office


(PAO),, unto the Honorable City Prosecutor, most respectfully aver(s), that:

1. Respondent on December 22, 2018, 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;

2. Today, January 1, 2019, appears to be the last day for the submission of
respondent’s counter-affidavit and other supporting documents;

3. There is a need to further study the case and to gather relevant


evidence to support the defense of the Respondent, thus, this request for a period of
ten (10) day extension within which to submit the respondent’s Counter-Affidavit and
other supporting documents;

4. 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, it is respectfully prayed of the Honorable


Prosecutor that this Motion, praying for an extension of TEN (10) DAYS within which to
submit Respondent’s Counter-Affidavit and supporting documents, be granted.

January 1,
, at the City of Tacloban, Philippines.
2019

PUBLIC ATTORNEY’S OFFICE


Department of Justice
TACLOBAN CITY DISTRICT OFFICE

By:

ATTY. CINDY HAN


Public Attorney III
#8 Bulwagan ng Katarungan, Magsaysay Blvd.,
Tacloban City
Attys. Roll No. 34380/ April 1, 2000
IBP OR No. 542682/04/02/08/Tacloban City
PTR No. 764523/04/04/08/Tacloban City
MCLE Compliance No. III-0009876, 11-23-2010
Contact No.: 09876453421/ 321-1234
Email address: cindyhanmo@gmail.com

CONFORME:

TEOFISTO R. ALCON
NOTICE

The Clerk
Office of the City Prosecutor, Tacloban City

GREETINGS:

Please submit the foregoing motion for the consideration of the Honorable City
Prosecutor immediately upon receipt hereof without further oral argument.

ATTY. CINDY HAN

Copy furnished:

MARIA JOSEFINA B. CRUZ

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