Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
PROVINCIAL PROSECUTION OFFICE
AGUSAN DEL NORTE
Hall of Justice
Libertad, Butuan City

PSINSP RALPH ANTHONY M. NPS DOCKET NO. XIII-02-

DEL PARTO, PNP-CARMEN, INV-18I-00218
ADN
Complainant,

-versus- FOR: “VIOL. OF R.A. 9165”

SEIGFREDO/WILFREDO H.
MANTALABA
Respondent.
x- --------------------x

MOTION FOR EXTENSION OF TIME

TO SUBMIT COUNTER-AFFIDAVIT

Respondent, through counsel, unto this Honorable Office, most

respectfully states that:

1. On September 26, 2018, respondent received a subpoena directing

him to submit a counter-affidavit and other supporting documents to
the charge against him until October 04, 2018;

2. Respondents engaged the services of the undersigned counsel only

today, that is, October 02, 2018;

3. Due to pressures of equally urgent professional work and prior

commitments, the undersigned counsel will not be able to meet the
said deadline;

4. As such, undersigned counsel is constrained to request for an

additional period of 10 days from today or until October 12, 2018
within which to submit his Counter-Affidavit. Moreover, this
additional time will also allow the undersigned to interview the
available witnesses and further study the instant case;

5. This Motion is not intended for delay but solely due to the foregoing
reasons.

Motion for Extension of Time 1|Page

 PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully prayed

unto the Honorable Office that respondent be given an additional period of
10 days from today or until October 12, 2018 within which to submit
his Counter-Affidavit.

Other reliefs just and equitable under the premises are likewise
prayed for.

Respectfully submitted, October 02, 2018, at Davao City, (for Butuan

City), Philippines.

CHRISTIAN D. DERIGAY
Counsel for the Respondent
M.C.L.E. Comp. No. IV-0021708
TIN: 428-708-196-000;
Roll No: 60035
IBP No. 048437/07-24-18
PTR No. 1101514C 09/07/18
Door 11, G/F, Plaza de Tavera Bldg., J. Camus Ext., Brgy 9-A, Davao City

Copy Furnished thru registered mail:

PSINSP RALPH ANTHONY M. DEL PARTO

Carmen Municipal Police Station
Carmen, Agusan del Norte

EXPLANATION
(Pursuant to section 13, Rule 14, of the Rules of Court)

Service of this Motion to the complainant was coursed through

registered mail considering the distance and for lack of personnel thereby
making personal service impossible.

Christian D. Derigay

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