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Motion for Additional Time in Cybercrime Case

The respondent Mary Luna V. Miranda is requesting additional time to submit a counter-affidavit in response to a complaint filed against her for alleged violations of the Cybercrime Prevention Act of 2012. Respondent's counsel is currently busy with other legal matters and needs more time to adequately study the case. The motion requests a 10-day extension until January 7, 2019 to submit the counter-affidavit. The motion is being sent to the Office of the Assistant Provincial Prosecutor in Ormoc City for consideration.

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Mikko Acuba
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83 views4 pages

Motion for Additional Time in Cybercrime Case

The respondent Mary Luna V. Miranda is requesting additional time to submit a counter-affidavit in response to a complaint filed against her for alleged violations of the Cybercrime Prevention Act of 2012. Respondent's counsel is currently busy with other legal matters and needs more time to adequately study the case. The motion requests a 10-day extension until January 7, 2019 to submit the counter-affidavit. The motion is being sent to the Office of the Assistant Provincial Prosecutor in Ormoc City for consideration.

Uploaded by

Mikko Acuba
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Samar
Catbalogan City

THE PEOPLE OF THE PHILIPPINES NPS DOCKET NO. VIII-


09-INV-19AI-00901

-versus -
FOR: VIOL. OF SEC.4 (4)
UNDER CYBERCRIME
PREVENTION ACT OF
2012 (RA NO. 10175) IN
REL TO ART 355 OF THE
RPC

MARY LUNA V. MIRANDA


Respondent
x---------------------------------------x

MOTION FOR ADDITIONAL TIME

COMES NOW respondent by counsel and unto the


Honorable Office respectfully states that:
1. On 05 DECEMBER 2018, respondent received the
subpoena dated 19 November 2018 directing the respondent
to submit within ten (10) days from receipt thereof his counter-
affidavit to the complaint and with the given period,
respondent had until 17 December 2018 to comply therewith;

2. His counsel, whom he just engaged last 12 December


2018 is presently laden with professional chores consisting of
almost daily-court appearances and preparation of equally-
important pleadings, apart from the need to intelligently study
the case, that he needs a non-extendible period within which
to file the desired pleadings;

3. The motion is made in good faith and never intended to


delay the disposition of this case, but solely due to valid reasons
herein set forth.

WHEREFORE, premises considered, it is respectfully prayed


of the Honorable Office that herein respondent be given an
additional period of ten (10) days from 27 December 2018 or
until 7 January 2019 to file said counter-affidavit to the said
complaint.

Catbalogan City, for Ormoc City, 27 December 2018.

ACUBA AND ACUBA LAW OFFICES


Counsel for Respondent
196 G/F Laohoo Bldg., San Bartolome St.
Brgy. 3, Catbalogan City, Samar

By:

DEMETRIO MEDINO J. ACUBA


Ground Floor, Laohoo Bldg.
196 San Bartolome St.
Brgy. 3, Catbalogan City, Samar
IBP No. 0039892, May 08, 2018
PTR No. 5694043, 6. 19.2018 Catbalogan City
Roll of Attorneys No.71321
MCLE Exempt

REQUEST

OFFICE OF THE ASSISTANT PROVINCIAL PROSECUTOR


Hall of Justice
Ormoc City

GREETINGS:

Immediately upon receipt hereof, kindly submit the


foregoing “Motion for Additional Time” to the Honorable Office
for its appropriate consideration.

ATTY. DEMETRIO MEDINO J. ACUBA

Cc: (By Registered Mail due to Distance)

OFFICE OF THE ASSISTANT PROVINCIAL PROSECUTOR


Hall of Justice
Ormoc City

GENE ROSE M. ARGENIO


Purok 3, Brgy. Bunu-anan,
Catbalogan City, Samar

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