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Motion for Extension in Trafficking Case

This document is a motion for extension of time filed by counsels Juril B. Patiño and Habeas Corpuz on behalf of their client Daniel Alan Nielsen. Nielsen was arrested without a warrant on August 4, 2015 for alleged violation of Section 4, paragraph A of Republic Act 10364. Counsels request a 5-day extension to submit counter-affidavits and supporting evidence, which were originally due on August 10, 2015. The extension is needed due to counsels' other professional commitments and holidays falling on August 6, 8, and 9. Granting the extension will also allow counsels to further interview witnesses and study the case.

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272 views3 pages

Motion for Extension in Trafficking Case

This document is a motion for extension of time filed by counsels Juril B. Patiño and Habeas Corpuz on behalf of their client Daniel Alan Nielsen. Nielsen was arrested without a warrant on August 4, 2015 for alleged violation of Section 4, paragraph A of Republic Act 10364. Counsels request a 5-day extension to submit counter-affidavits and supporting evidence, which were originally due on August 10, 2015. The extension is needed due to counsels' other professional commitments and holidays falling on August 6, 8, and 9. Granting the extension will also allow counsels to further interview witnesses and study the case.

Uploaded by

Juril Patiño
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

Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROVINCIAL PROSECUTOR
Capitol, Cebu City

PNP SAN FERNANDO CEBU,


Complainant,
NPS Docket No. 03-INQ-15H-1254
For: Qualified Trafficking
(Sec. 4, par. A of RA 10364)

-vsDANIEL ALAN NIELSEN,


Respondent.
x-----------------------------------------/

MOTION FOR EXTENSION OF TIME


RESPONDENT, by the undersigned counsels, and unto this
Honorable Office, most respectfully states that:
1. Respondent engaged the services of the undersigned counsels after
he was arrested without warrant for violation of Sec. 4, par. A of R.A 10364
on August 04,2015 ;
2. Respondent refused to undergo an inquest proceeding and requested
for a preliminary investigation ;
3. Respondent was given five (5) days within which to file his
counter-affidavit and other supporting evidence which five days commence
to run on August 06, 2015, hence, the fifth day reglementary period is due
on August 10,2015 ;
4. However, due to the pressures of equally urgent professional work
and prior commitments and time constraints by reason of holiday on August
6, Cebu Provincial Charter Day and non-working days on August 8 and 9
(Saturday and Sunday) the undersigned counsels will not be able to meet the
said deadline;
5. As such, undersigned counsel is constrained to request for an
additional period of five (5) days from today within which to submit
1

Respondents counter-affidavit and supporting evidence. Moreover, this


additional time will also allow the undersigned to interview the available
witness and study this case further;
5. This motion is not intended for delay but solely due to the foregoing
reasons.
P R AYE R
WHEREFORE, Respondent most respectfully prays of this
Honorable Office that he be given an additional period of FIVE (5) days
from today within which to submit counter-affidavits and other supporting
evidences.
Other relief just and equitable are likewise prayed for.
Cebu City, Philippines, August 10, 2015.
RESPECTFULLY SUBMITTED.

LOON CORPUZ PATIO AND ASSOCIATES


(Counsel of the Accused)
G/F GMC Plaza Bldg. Legaspi Extension
corner M.J Cuenco St, Cebu City, Philippines
Tel No. (032) 254-0453

By:

JURIL B. PATIO
Roll of Attorney No. 63966 April 27,2015
PTR OR No. 707854 5-06-15
IBP OR No. 0997508 4-27-15 Cebu City Chapter
MCLE COMPLIANCE No. Exempt-New Passer
Email add: [email protected]

HABEAS CORPUZ
Roll of Attorney No. 62850 May 06,2014
PTR OR No. 599058 January 07,2015 Cebu City
IBP OR No. 966627 January 7,2015 Cebu City Chapter
MCLE COMPLIANCE No. Exempt-New Passer
Email add: [email protected]

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