1

Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
Office of the City Prosecutor
Zamboanga City
MOTION FOR EXTENSION OF TIME
TO FILE COUNTER AFFIDAVIT
RE: NPS DOCKET NO.IX-06-INQ-16F-00474
X------------------------------------------------------------------------x
EX-PARTE MOTION FOR EXTENSION OF TIME
TO FILE COUNTER-AFFIDAVIT WITH WAIVER
COMES NOW, Respondent DEXTER PIOQUINTO y JALA
through undersigned counsel and unto this Honorable Office, most
respectfully states that:
1. The Subpoena of the Honorable Office dated 8 June 2016
was duly received by Respondent on the same day, requiring
him to file and submit his Counter-Affidavit within ten (10)
days from receipt thereof, thus he has until 18 June 2016
within which to file and submit the same;
2. However, considering that Respondent has just recently
engaged the services of the undersigned counsel today and
that counsel needs more time to study the case, and to
confer with him and his witnesses in preparing an intelligible
defense in their counter-affidavits. The undersigned
anticipates that he will not be able to file the CounterAffidavit of Respondent within the period provided. Thus, he
is constrained to ask for an extension of TEN (10) days from
16 June 2016 or until 26 June 2016 within which to file and
submit his Counter-Affidavit. Respondent likewise requests
for extension of Waiver of the provisions of Article 125 of the
Revised Penal Code for FIFTEEN (15) days from 16 June
2016 or until 01 July 2016;
3. Undersigned Counsel most respectfully manifests sincerity in
the relief prayed for herein and that the same is not in any
way intended to delay the proceedings hereof.
PRAYE R

WHEREFORE, it is most respectfully prayed of this Honorable

Office that Respondent be given an additional period of TEN (10)
days from 16 June 2016 or until 26 June 2016 within which to file and
submit his Counter-Affidavit. Respondent likewise requests for
extension of Waiver of the provisions of Article 125 of the Revised
Penal Code for FIFTEEN (15) days from 26 June 2016 or until 01
July 2016.
Other reliefs as may be just and equitable under the premises
are likewise prayed for.
City of Zamboanga, Philippines, 16 June 2016.
The Receiving Clerk
Office of the City Prosecutor
Hall of Justice, Sta. Barbara
Zamboanga City
Greetings!
Please take notice that the undersigned counsel is submitting
the foregoing Ex-Parte Motion for Extension of Time to file CounterAffidavit with Waiver for the consideration and approval of this
Honorable Office without need of oral argument.