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 Respondents 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. PRAYER 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__. (COUNSEL) (NOTICE OF HEARING) (EXPLANATION) COPY FURNISHED: OPPOSING COUNSEL