The respondent, KEVIN RAY HAVERS, unto this Honorable City Prosecutor, most respectfully
prays that he be granted an extension of fifteen (15) days from July 11, 2010, his last day to file
his counter-affidavit and those of his witnesses having received the subpoena together with a
copy of the Complaint-Affidavit on July 1, 2010 on the ground that he is still looking for a
counsel of his own choice to assist him in the above-entitled case. 1. Respondent was arrested
and detained in the Dumaguete City Police Station from April 26, 2019 until April 29, 2019. On
April 29, 2019, respondent
received a
subpoena from the Prosecutor’s Office charging him of the above-stated offense and requiring
him to submit his counter-affidavit and other supporting documents within (ten)10 days from
receipt thereof; 2.
Today,
, appears to be the last day for the submission of
respondent(s’) counter-affidavit and other supporting documents; 3.
There is a need to further study the case and to gather relevant evidence to
support the defense/s of the Respondent(s), thus, this request for a period of ten (10) day
extension within which to submit the respondent(s’) Counter-Affidavit and other supporting
documents;
4. That the filing of this motion is done in good faith and not for purposes of delaying the
proceedings of this case but for the reason above-stated.
PRAYER WHEREFORE, premises considered, it is respectfully prayed of the Honorable
Prosecutor that this Motion, praying for an extension of TEN (10) DAYS within which to submit
Respondent’s Counter-Affidavit and supporting documents, be granted.
(date)
, at the City/Municipality/Province of
, Philippines.
PUBLIC ATTORNEY’S OFFICE Department of Justice DISTRICT OFFICE
By: ATTY. Public Attorney Roll No. IBP No. MCLE Comp. No. IIICONFORME:
(respondent)
NOTICE
The Clerk Office of the City/Municipality/ Provincial Prosecutor/City/Munici pality/ Province of
GREETINGS: Please submit the foregoing motion for the consideration of the Honorable City
Prosecutor immediately upon receipt hereof without further oral argument.
ATTY. Copy furnished: (Complainant / counsel for the complainant) This motion is not intended
to delay the proceedings of the case. Dumaguete City, Philippines, this 2nd day of May 2019.
KEVIN RAY HAVERS Hermogina Apartments, Calindagan, Dumaguete City
SUBSCRIBED AND SWORN to before me, a Notary Public in and for
______________________________, this _____ day of _____________, 2010, at
_______________________. Affiant exhibited to me his _______________________________.
I further certify that I personally examined the affiant and I am satisfied that he understood it and
that he voluntarily executed the same.
Doc. No. _____; Page No. _____; Book No. _____; Series of 2019. Copy Furnished by
Registered Mail to: CORNELIO CHITO M. DELA PEÑA OIC- Chiel, Legal Divison
Revenue District office Ilagan, Isabela JOCELYN LORA Revenue District Office No. 15 Ilagan,
Isabela LORNA B. BINARAO Revenue District Office No. 15 Ilagan, Isabela REQUEST: The
Clerk of the Provincial Prosecutor Justice Hall, Ilagan, Isabela Greetings: Immediately upon
receipt hereof, kindly submit the foregoing Motion to the Honorable Provincial Prosecutor for
his consideration, approval and resolution, with or without complainant’s comment/opposition
thereto. BERNARD Q. LIM Respondent
EXPLANATION Copies of the foregoing Motion for Extension of Time to File
CounterAffidavit were served on the Affiants and the OIC-Chief of Legal Division of Revenue
District Office, Ilagan, Isabela by registered mail since personal service is not practicable in view
of time constraint and the distance between the residence of the petitioner and the Office of the
Affiants.
BERNARD Q. LIM Respondent
