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Motion for Extension to Submit Counter-Affidavit

The respondent filed a motion for an extension of time to submit his counter-affidavit in response to charges of multiple serious physical injury and damage to property. He requests additional time because he is currently working as an active seafarer aboard an international shipping vessel since December 2022, making it difficult to submit the documents or appoint a representative in person. The respondent asks that he be given until an unspecified future date to file his counter-affidavit and supporting documents with the prosecutor's office.

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69 views2 pages

Motion for Extension to Submit Counter-Affidavit

The respondent filed a motion for an extension of time to submit his counter-affidavit in response to charges of multiple serious physical injury and damage to property. He requests additional time because he is currently working as an active seafarer aboard an international shipping vessel since December 2022, making it difficult to submit the documents or appoint a representative in person. The respondent asks that he be given until an unspecified future date to file his counter-affidavit and supporting documents with the prosecutor's office.

Uploaded by

Tobz Fernndz
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, Region III
Office of the Provincial Prosecutor
Malolos City, Bulacan
 
PEDRO C. BAGO,
 I.S. NO. III-04-INV-23A-00014
Complainant,
FOR: RIR Multiple Serious Physical Injury
and Damage to Property (Art. 365 ,
RPC)
 -versus-

THANNIE JERUZ DAVID SANTOS,


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

Respondent,

MOTION FOR EXTENSION OF TIME


TO SUBMIT COUNTER-AFFIDAVIT
 
The above-named respondent, herein represented by his brother _________________________,
unto the Honorable City Prosecutor, most respectfully aver(s), that:

1. Respondent on February 18, 2023, through the undersigned, received a subpoena from the
Prosecutor’s  Office charging him of the above-statedoffense and requiring him to submit his
counter-affidavit and other supporting documents within (ten)10 days from receipt thereof;

2. Today, February 27, 2023, appears to be two (2) days before the deadline for the submission of 
Respondent’s  counter-affidavit and other supporting documents;

3. Respondent is an active Seafarer and is currently on board a maritime vessel in international


shipping since December ___ 2022, a copy of his Seaman’s Book and Phillippine Passport is
hereto attached as Exhibit A and Exhibit B ;

4. As such seafarer, he cannot personally appear before the Prosecutor’s Office for
the submission of his Counter-Affidavit ;

5. Above-named Respondent cannot easily execute any Special Power of Attorney in


behalf of his representative due to his professional employment ;

6. Respondent respectfully requests that he be given an extension of time until


______________ within which he would file his counter affidavit with this
Honorable Office ;

7. That the filing of this motion is done in good faith and not for the purpose of
delaying the proceedings of this case but for the reason/s above-stated ;
P R A Y E R

WHEREFORE, , premises considered, it is respectfully prayed of theHonorable


Prosecutor that this Motion, praying for an extension of ___________(_____) DAYS, within which to
submit
Respondent’s  Counter-Affidavit and supporting documents, be granted.

February 27, 2023, at the City of Malolos, Province of Bulacan, Philippines.

PEDRO SANTOS
Representative for Respondent

Conforme :

THANNIE JERUZ DAVID SANTOS


Respondent

NOTICE

The CLERK
Office of the Provincial Prosecutor
Malolos City, Bulacan

GREETINGS :

Please submit the foregoing motion for the consideration of the Honorable
Prosecutor immediately upon receipt hereof without further oral argument.

PEDRO SANTOS
Representative for Respondent

Copy Furnished :

Pedro C. Bago
Gen. Tinio, Nueva Ecija

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