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    Motion For Extension of Time-Sayno

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    cheryl ann
    Jolly Ann B. Sayno submitted a motion to the Office of the City Prosecutor of Pasig City requesting a 7-day extension to file her counter-affidavit in response to a qualified theft complaint filed against her by CVM Pawnshop and Money Changer Corp. She stated that she received the subpoena after the original filing deadline and needs more time to find legal counsel and gather supporting documents for her defense. She asserted that the extension is not intended to delay the case but is necessary due to the circumstances.

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    Motion For Extension of Time-Sayno

    Uploaded by

    cheryl ann
    49 views3 pages
    Jolly Ann B. Sayno submitted a motion to the Office of the City Prosecutor of Pasig City requesting a 7-day extension to file her counter-affidavit in response to a qualified theft complaint filed against her by CVM Pawnshop and Money Changer Corp. She stated that she received the subpoena after the original filing deadline and needs more time to find legal counsel and gather supporting documents for her defense. She asserted that the extension is not intended to delay the case but is necessary due to the circumstances.

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    Motion for Extension of Time-Sayno

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    Jolly Ann B. Sayno submitted a motion to the Office of the City Prosecutor of Pasig City requesting a 7-day extension to file her counter-affidavit in response to a qualified theft complaint filed against her by CVM Pawnshop and Money Changer Corp. She stated that she received the subpoena after the original filing deadline and needs more time to find legal counsel and gather supporting documents for her defense. She asserted that the extension is not intended to delay the case but is necessary due to the circumstances.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    49 views3 pages

    Motion For Extension of Time-Sayno

    Uploaded by

    cheryl ann
    Jolly Ann B. Sayno submitted a motion to the Office of the City Prosecutor of Pasig City requesting a 7-day extension to file her counter-affidavit in response to a qualified theft complaint filed against her by CVM Pawnshop and Money Changer Corp. She stated that she received the subpoena after the original filing deadline and needs more time to find legal counsel and gather supporting documents for her defense. She asserted that the extension is not intended to delay the case but is necessary due to the circumstances.

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    Republic of the Philippines

    DEPARTMENT OF JUSTICE
    OFFICE OF THE CITY PROSECUTOR
    Pasig City

    CVM PAWNSHOP AND MONEY I.S. No. XV-14-INV-21F-


    CHANGER CORP., represented 00899
    by MARVIN ROJAS y NICOLAS,
    Complainant/s,

    -versus- FOR: Qualified Theft

    JOLLY ANN SAYNO y


    BAYBAYAN,
    Respondent.

    MOTION FOR EXTENSION OF TIME


    TO FILE COUNTER-AFFIDAVIT

    The undersigned RESPONDENT JOLLY ANN B. SAYNO, unto


    this Honorable Office of the City Prosecutor, most
    respectfully states:

    1. The Honorable Prosecutor issued Subpoena dated June


    22, 2021 directing herein Respondent to file her
    Counter-Affidavit on July 06, 2021 at 10:00 A.M.

    2. With all due respect, as much as the Respondent


    would want to file her Counter-Affidavit on the period
    stated in the Subpoena, herein Respondent could not do
    so because she received the Subpoena only on July 8,
    2021.

    3. The herein Respondent is still looking for counsel


    who can assist her in the preparation of her Counter-
    Affidavit.

    4. As such, undersigned Respondent is constrained to


    request for an additional period of seven (7) days from
    July 13, 2021 within which to submit her Counter-
    Affidavit and other supporting evidence. Moreover, the
    additional time would allow herein Respondent to gather
    all the documents she needed for her defense.

    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 Pasig that she be
    given an additional period of seven (7) days from July
    13, 2021 within which to submit her Counter-Affidavit
    and other documentary evidence.

    Other reliefs just and equitable are likewise


    prayed for.

    RESPECTFULLY SUBMITTED

    JOLLY ANN B. SAYNO


    Respondent

    Copy furnished:

    CVM Pawnshop and Money


    Changer Corp., represented by
    Marvin Rojas y Nicolas
    Unit 1722 17th Floor City and Land
    Mega Plaza Condominium
    Garnet Road, Ortigas Center, Brgy. San Antonio
    Pasig City.

    EXPLANATION

    A copy of this Motion is served to the other party


    via registered mail and/or private courier services due
    to lack of material time and distance.
    JOLLY ANN B. SAYNO

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