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Republic of the Philippines

Fifth Judicial Region

REGIONAL TRIAL COURT

Branch

Sorsogon City

MOTION FOR EXTENSION OF TIME

RESPONDENT, Noel Ayo Dioneda, by the undersigned counsel, and unto this
Honorable Court, most respectfully states that:

1. Respondent engaged the services of undersigned counsel only on August 25, 2017;

2. Respondent received the subpoena on August __ , 2017 and thus has until August
24, 2017 within which to submit his counter-affidavit, that of his witnesses and other
supporting documents;

3. However, it was only now that the respondent was able to engage the services of
the counsel, and due to the pressures of equally urgent professional work and prior
commitments together with the lack of electricity yesterday, the undersigned
counsel was not able to meet the said deadline;

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


ten (10) days from August 25, 2017 or until September 4, 2017
within which to submit the following documents. Moreover, this additional time will
also allow the counsel to interview the available witness and study this case.

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

PRAYER

WHEREFORE, Respondent most respectfully prays of this Honorable Court that he be


given an additional period of ten (10) days from today within which to submit the
counter- affidavit and other documentary evidence.

Other relief just and equitable are likewise prayed for.


Sorsogon City, Philippines, August 25, 2017.

RON ELY L. ESPINOSA


Counsel for the Respondent
Burgos St., Polvorista, East District
Sorsogon City
PTR No. 0124045/ January 9, 2017/ SORSOGON CITY
IBP NO. 1070235/ January 30, 2017/ SORSOGON CITY
ROLL No. 61952
MCLE Compliance No. V- 0006078
February 4, 2015

NOTICE OF HEARING

City Prosecution Office


Sorsogon City

The Branch Clerk of Court


RTC Sorsogon City Branch 53
EXPLANATION

Copy of the foregoing was furnished the above party by ________________.

COPY FURNISHED:

OPPOSING COUNSEL