MOTION FOR EXTENSION OF TIME
Respondent, by the undersigned counsel, and unto this Honorable Office of the City Prosecutor, most respectfully states that:
1. Respondent engaged the services of undersigned counsel only on _____________;
2. Respondent received the subpoena on _____________ and thus has until _____________ within which to submit his counter-affidavit;
3. However, due to the 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 _____________ from today within which to submit Respondent’s counter-affidavit and other supporting evidence. Moreover, this additional time will also allow the undersigned to interview the available witness and study this case;
5. This Motion is not intended for delay but solely due to the foregoing reasons.
P R A Y E R
WHEREFORE, Respondent most respectfully prays of this Honorable City Prosecutor of _____________ that he be given an additional period of _____________ from today within which to submit his counter-affidavit and other documentary evidence.
MOST RESPECTFULLY SUBMITTED.
Other relief just and equitable are likewise prayed for.
_____________, Philippines, __Date__.
(NOTICE OF HEARING)