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National Prosecution Service

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mark villamor
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36 views3 pages

National Prosecution Service

education

Uploaded by

mark villamor
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR

xxxxxx
xxxx
Petitioner
,
Criminal Case No. IV-28-INV-
20K-0922
-versus- For: Libel in relation to
Republic Act 10175

xxxxx xxxx
Respondent
.
x - - - - - - - - - - - - - - - - - - - - - - -x

MOTION FOR EXTENSION OF TIME TO FILE POSITION


PAPER

RESPONDENT, unto this Honorable Office, respectfully avers


THAT:

1. On ______________, the respondent received the copy of


the Order of Subpoena dated ________________.

2. However, due to volume and pressure of work, coupled


with other equally important and urgent professional commitments,
the respondent will not be able to meet the said deadline; thus, the
respondent is constrained to request for an additional time to study
the case further.

3. Further, the respondent did not have the opportunity to


gather other documentary evidence to support its defense
considering that the National Capital Region is still placed under
General Community Quarantine.

1
4. Thus, it is respectfully prayed that this Honorable Court
grant an extension of ten (10) days from today 28 December 2020
within which to file the position paper.

5. This Motion is not intended to delay the proceedings in


this case but is merely compelled by the reasons aforestated.

PRAYER

WHEREFORE, above premises considered, it is respectfully


prayed that this Honorable Office grant the respondent an additional
ten (10) days from 28 December 2020 or until 06 January 2021 within
which to file the position paper.

Other relief and remedies, just and equitable under the


premises are likewise prayed for. 

RESPECTFULLY SUBMITTED.

Laguna for Pasig City; 28 December 2020.

By:

xxxxxx,
xxxx

Copy Furnished through registered mail:

xxxxxx
xxxx

EXPLANATION

In compliance with Rules of Civil Procedure, the foregoing is


filed and served by registered mail to the opposing party given that it
is impracticable to file and serve the same by personal service due to
distance and time considerations.

2
NOTICE OF SUBMISSION

REPUBLIC OF THE PHILIPPINES


DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR

Due to its non-litigious nature, the respondent submits the


foregoing “Motion For Extension of Time to File Position Paper” for
the consideration and approval of the Honorable Office upon receipt
thereof xxxxxwithout need of further oral argument.

xxxxxxx

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