NATIONAL POLICE COI!!ION P"ILIPPINE NATIONAL POLICE NCR CRIINAL IN#E!TIGATION AND DETENTION $NIT CRIINAL IN#E!TIGATION AND DETECTION GRO$P Camp Crame% &ue'on Cit( P"ILIPPINE NATIONAL POLICE% Complainant% AD) CA!E NO) ********** + versus + ,OR - GRA#E I!COND$CT .!erious Ph(sical In/uries 0 Arbitrar( Detention1 **************************** Respondents) 2 + + + + + + + + + + + + + + + + + + + + + + + 2 MANIFESTATION RE : SUBMISSION OF HIS COUNTER- AFFIDAVIT WITH PRAYER FOR EXTENSION OF TIME TO SUBMIT ADDITIONAL AFFIDAVITS OF HIS WITNESSES COE! NO3 RE!PONDENT4O#ANT ***********************% thru counsel% and before this "onorable Office% he most respectfull( alle5es and manifests that- 6) "e is submittin5 toda(% *************% his counter+affidavit in compliance 7ith the earlier instructions 5iven to him last 7ee8) 9% "o7ever% he has other 7itnesses to support his stand and 7ho are li8e7ise 7illin5 to e2ecute statements to prop up his defense) "e needs time to obtain their affidavits for 7hich reason he be5s for leave that he be 5iven an additional period of ten .6:1 da(s from toda( to submit his 7itnesses; affidavits) 3"ERE,ORE% PREI!E! CON!IDERED% it is most respectfull( pra(ed that he be 5iven an additional period of ten .6:1 da(s from toda( to submit his 7itnesses; affidavits and other documentar( e2hibits) + Pa5e 9 + &ue'on Cit(% etro anila ********************** Counsel for Respondent4ovant
************************* Complainant ************************* ************************* G R E E T I N G ! - Please ta8e notice that the undersi5ned 7ill submit the fore5oin5 manifestation and motion for consideration of the !ummar( "earin5 Officer upon its receipt) ************************ Cop( furnished- ************************* Private Complainant E X P L A N A T I O N Considerin5 the distance involved bet7een his office and the office of the private complainant and as he has no office messen5er to effect a personal service of a cop( of the fore5oin5 pleadin5 her cop( 7as served throu5h the mails as evidenced b( the re5istr( receipt attached) ***************************