Motion Filed In Court.docx

REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION QUEZON CITY, BRANCH PEOPLE OF , Accused. CRIMINAL CASE NO. FOR: Violation of Section 10(a) of R.A. 7610 x------------------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE COMMENT (RE: MOTION TO DEFER ARRAIGNMENT AND SUSPEND PROCEEDINGS) The private complainant (the “private complainant”), represented by his father, through the undersigned counsel, unto this Honorable Court, respectfully states: 1. On the 06 December 2018 setting for arraignment of ( “the accused”), the accused, through counsel, apprised the Honorable Court regarding their pending Motion to Defer Arraignment and Suspend Proceeding (the “Motion”). On the same hearing, the undersigned counsel respectfully entered its appearance as private prosecutor, under the direct control and supervision of the public prosecutor. 2. Likewise, on the same hearing, one of the associates of the undersigned law firm, orally manifested, on behalf of the private complainant, his comment on the Motion by the accused. Nevertheless, the court inquired whether the private complainant, through counsel, is still willing to reduce its comment in writing and file the same in court, to which atty. replied in the affirmative. Hence the court, gave the private complainant five (5) days within which to file its written comment. 3. Unfortunately, on 7 December 2018, the brother of atty. mother died. As a consequence, had to join the family mourning. As a result, was only able to finish the comment on 11 December 2018. But since it has to be signed as well by the public prosecutor, it could not be filed on time. For this reason, the undersigned counsel respectfully

requests for a 2-day extension to file the said comment or until 13 December 2018. 4. This Motion is being filed solely for the reason given above and is not meant to delay the proceedings.

PRAYER WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court that the private complainant be granted an additional period of two (2) days or until 13 December 2018, within which to file its Comment to the Motion filed by the accused. The private complainant likewise prays for such other measures of relief as this Honorable Court may deem just and equitable under the premises. Respectfully submitted. Muntinlupa City for Quezon City, 11 December 2018.

Counsel for the Private By:

Copy Furnished:

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EXPLANATION (Pursuant to Rule 13, Sec. 11 of the 1997 Rules of Civil Procedure)

The filing and service of the foregoing Motion to the above parties were made by registered mail due to time constraints and lack of adequate personnel in the undersigned counsel’s Law Firm to effect personal filing and service thereof.

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