REPUBLIC OF THE PHILIPPINES

PROVINCE OF ILOCOS NORTE

DEPARTMENT OF JUSTICE (NPS)
OFFICE OF THE PROVINCIAL PROSECUTOR
BATAC CITY BRANCH

ARJAY V. SALIVIO,
Complainant,

-versus- NPS DOCKET NO. I-04-INV-19K-

00365
MELINDA P. ANDAY,
Respondent.
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MOTION FOR EXTENSION TO FILE

COUNTER-AFFIDAVIT

COMES NOW RESPONDENT, through the undersigned counsel,

unto this Most Honorable Office, most respectfully alleges: That-

On December 1, 2019, the undersigned respondent received a copy

of the SUBPOENA issued by this Honorable Office directing her to file her
COUNTER-AFFIDAVIT and other pieces of evidence relevant to her
defense within TEN (10) DAYS from receipt thereof or until December
10, 2019.

Unfortunately, such period proved to be insufficient for the

undersigned counsel to review and study the entire records of the case
considering that she has just been recently engaged.

Thus, in the greater interest of justice and in order to provide the

accused adequate preparation to refute the complaint filed against her,
the undersigned counsel is now constrained to request an additional TEN
(10) DAYS from today or until DECEMBER 17, 2019, to submit the
respondent’s counter-affidavit.

It is not the intention of the respondent or the undersigned counsel

to delay the speedy disposition of the instant case but only for the
foregoing reasons.

WHEREFORE, in the interest of justice and fair play, it is

respectfully prayed of this Most Honorable Office to grant the respondent
an extension of TEN (10) DAYS from today or until DECEMBER 10, 2019
within which to file respondent’s counter-affidavit and other pieces of
evidence.
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 Other reliefs that are just and equitable under the premises are
likewise prayed for.

RESPECTFULLY & COURTEOUSLY SUBMITTED. Laoag City for

Batac City, Philippines. December 10, 2019.

ATTY. ROZANNA BIANCA T. PASTOR

Counsel for Respondent
Roll of Attorney’s No. 73773 | 20 June 2019
IBP No. 087333 | 20 May 2019
PTR No. 1916693 | 24 June 2019 / Laoag City
MCLE Compliance No. (Admitted 20 June 2019)
TIN: 755-983-671-000
Address: Manuel, Nicolas & Perera Law Offices
#62 Rizal Street, Brgy. 6, Laoag City 2900 Philippines
Landline: (077) 771-47-44 | Mobile: (+63) 939 938 2806

Copy Furnished:
ARJAY V. SALIVIO Reg. Receipt No. ______________
Brgy. 7 San Pedro 2, Date: __________________________
Bacarra, 2916 Ilocos Norte