Republic of the Philippines

DEPARTMENT OF JUSTICE
Province of South Cotabato
PROVINCIAL PROSECUTION OFFICE
Hall of Justice, Koronadal City

JENEFLOREM TUBAT y VELETE NPS Docket No.

Complainant,
XII-08a-INV-17H-00353
- versus –
VIOLATION OF R.A. 9262
EMILIO TUBAT y SEVILLA,
Respondent.
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MOTION FOR EXTENSION OF TIME

Respondent, by the undersigned counsel, and unto this

Honorable Office of the Provincial Prosecutor, most respectfully states
that:

1. Respondent engaged the services of undersigned counsel

only yesterday, September 4, 2017 after he was denied legal
assistance by the Public Attorney’s Office (PAO) due to conflict of
interest as, apparently, the Complainant was assisted by PAO in the
case preparation;

2. If Respondent’s memory is to be believed, he has until

today within which to submit his counter-affidavit and other
supporting evidence exculpatory in nature;

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 ten (10) days
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;
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5. This Motion is not intended for delay but solely

due to the foregoing reasons.

PRAYER

WHEREFORE, Respondent most respectfully prays of this

Honorable Provincial Prosecutor of South Cotabato that he be given
an additional period of ten (10) days 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.

Tupi for Koronadal City, September 5, 2017.

ATTY. REMIGIO P. ROJAS

Counsel for the Respondent
Tupi, South Cotabato
Roll of Attorney No. 40307
IBP No. 1070055/1-26-17/SocGen
PTR No. 2189513 /1-5-17SoCot
MCLE No. 0013840 /2-10-16