Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE XI
Office of the City Prosecutor
City of Davao

EVELYN T. ALBUT NPS Docket No. _______________

Plaintiff,

- versus - FOR:

HILARIO M. TAMBY,
Accused.
x--------------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE

COUNTER AFFIDAVIT

Respondent, by the undersigned counsel, and unto this

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

1. Respondent engaged the services of undersigned counsel only on

March 2, 2018;

2. Respondent received the subpoena on February 22, 2018 and thus has
until March 4, 2018within which to submit his counter-affidavit;

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 March 4, 2018 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;

5. This Motion is not intended for delay but solely due to the foregoing
reasons.

PRAYER

WHEREFORE, Respondent most respectfully prays of this Honorable

City Prosecutor that he be given an additional period of Ten (10) days
from March 4, 2018 within which to submit his counter-affidavit and other
documentary evidence.

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 MOST RESPECTFULLY SUBMITTED.

Other relief just and equitable are likewise prayed for.

Digos City, Davao del Sur, Philippines, March 2, 2018.

By:

ATTY. _________________________
Counsel for the Respondent
Roll of Attorney’s No. ________
IBP Number: __________ ; 01/04/18
PTR Number: __________ ; 01/03/18
MCLE Compliance No.: (NEW LAWYER) / May ____, 2____

Copy Furnished:

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