REPUBLIC OF THE PHILIPPINES Department of Justice OFFICE OF THE CITY PROSECUTOR Pasay City

CHARITO B. GUNNING Complainant, versus -

XV-13-INV-13-H-01534

For: PERJURY under Art 183 of the Revised Penal Code Crim Case No ____________

ROBERT GEORGE GUNNING Respondent/s xx

MOTION FOR EXTENSION OF TIME TO FILE COUNTER-AFFIDAVIT The respondent, by and through the undersigned counsel, moves this Court to extend the time for the submission of the Counter Affidavit, and as grounds therefore states: 1. That the respondent has been directed to file a Counter-Affidavit and other supporting documents by 24 September 2013. 2. That by reason of geographical location and distance between the respondent and the herein counsel, the Subpoena was only received by the latter on September 5, 2013. 3. That additional time is necessary to prepare the Counter Affidavit. 4. The undersigned counsel, however, anticipates his inability to file the Counter Affidavit on or before the said due date because of the tremendous pressure of other equally urgent professional work requiring the preparation of pleadings and almost daily trial appearances in various courts within and outside Metro Manila. For this reason, the undersigned is constrained to ask for an additional fifteen (15) days from 13 September 2013 until 28 September 2013, within which to submit respondents Counter-Affidavit. 5. That there will be No prejudice to the complainant in granting this request for extension of time to file the Counter-Affidavit. 6. That this motion is made in good faith, and not merely for purposes of delay. Wherefore, it is most respectfully prayed of this Honorable Court that the respondent be granted extension of another fifteen (15) days from 13 September 2013 until 28 September 2013 to submit his Counter Affidavit and other supporting documents for his defense. Bacolod City, Philippines, 12 September 2013.

(SGD) ATTY. JOVIM V. ENTILA Counsel for Respondent Unit 2 QL 358 Bldg. Gonzaga Street, Bacolod City Tel/Fax Nos. (034) 433-4157. 709-0341. 476-5973

THE RECEVING CLERK City Prosecutors Office Pasay City CHARITO B. GUNNING 2nd Street, MargaritaVillage, San Carlos City, Negros Occ. Please be informed that the undersigned counsel will submit the foregoing Motion immediately upon receipt hereof for the consideration and resolution of the Investigating Prosecutor, the same being non-litigious in nature.

Atty. Jovim V. Entila

Copy furnished by registered mail this 12 September 2013 to:

CHARITO B. GUNNING 2nd Street, MargaritaVillage, San Carlos City, Negros Occ. as evidenced by the attached Bacolod City Postal registry Receipt No._____

EXPLANATION This Motion was served to the complainant and for the Investigating Prosecutor via registered mail, personal service being impracticable due to distance.

Atty. Jovim V. Entila