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Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Zamboanga City

PO3 JOSEPH SAAVEDRA ROBLES,ET AL

Complainant, NPS DOCKET NO. IX-06-
INQ-164-00974

-versus- -for-

JOAN OBERA y ROMUALDO VIOLATION OF SECTION

5,11 &Art. II of R.A. 9165

Respondent.

X---------------------------------------------x

EX-PARTE MOTION FOR EXTENSION OF TIME

TO FILE COUNTER-AFFIDAVIT WITH ENTRY OF APPEARANCE AND
WAIVER

COMES NOW, Respondent JOAN OBERA y ROMUALDO through

undersigned counsel and unto this Honorable Office, most respectfully
state that:

1. Undersigned counsel most respectfully enters his appearance as

Counsel for Respondent JOAN OBERA y ROMUALDO
(Respondent for brevity), henceforth it is requested that the
undersigned be furnished with copies of motions, orders and other
papers emanating from this Honorable Office;

2. The Subpoena of the Honorable Office dated 08 October 2016

was duly received by Respondent on the same day, requiring them
to file and submit their Counter-Affidavit within ten (10) days from
receipt thereof, thus he has until 18 October 2016 within which to
file and submit the same;
3. However, considering that Respondent has just recently engaged
the services of the undersigned counsel and that counsel needs
more time to study the case, he anticipates that he will not be able
to file Respondents Counter-Affidavit within the period provided.
Thus, he is constrained to ask for an extension of TEN (10) days
from 18 October 2016 or until 28 October 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 28 October 2016 or until
2 November 2016;
 2

4. 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 18
October 2016 or until 28 October 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 28 October 2016 or until 2 November 2016.
Other reliefs as may be just and equitable under the premises are
likewise prayed for.

City of Zamboanga, Philippines, 17 October 2016.

GIAN PAOLO U. ENRIQUEZ

Counsel for Respondent
ENRIQUEZ CAPIN GAUGANO & ASSOCIATES LAW OFFICES
2nd Floor, LDM Bldg., Pilar St., Zamboanga City
PTR No. 0933265 - 01/04/16
IBP No. 897185 - 01/04/16
at Zamboanga City
Roll No.49871-05/02/05
MCLE Compliance No. III- 0012187-04/13/10
MCLE Compliance No. IV- 0000617-11/05/10
MCLE Compliance No. V- 0002658 06/19/14
At my behest:

JOAN R. OBERA

NOTICE OF HEARING

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 Counter-Affidavit
with Entry of Appearance and Waiver for the consideration and approval of
this Honorable Office without need of oral argument.

GIAN PAOLO U. ENRIQUEZ