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Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Tagum City, Davao del Norte

ESTHER V. VALIENTE,
Complainant,

-vs- NPS XI-03-INV-16F-00207


FOR: MEDICAL
MALPRACTICE/NEGLIGENCE

RHEA DOLOR C. BRILLANTES,


RICHARD T. MATA and BETHYL ISTURIS
Respondents.
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MOTION FOR EXTENSION OF TIME TO FILE MOTION


FOR RECONSIDERATION

COMES NOW, the undersigned complainant, to this


Honorable Office, most respectfully states that:

1. Complainant has engaged the services of another legal counsel based


at Mandaluyong City through her son, Jomar V. Valiente last August
10, 2016, and needs to review the case and prepare the reply affidavit;

2. Since Complainant received the counter-affidavits of the respondents


on July 27, 2016, it is directed by this Honorable Office to submit the
reply affidavit on or before August 17, 2016

3. However, due to the pressures of equally urgent professional work


and prior commitments, the legal counsel will not be able to meet the
said deadline;

4. This Motion is not intended for delay but solely due to the foregoing
reasons.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable


Office the Complainant to be given an additional period of ten (10) days
from August 17, 2016 within which to submit a Reply Affidavit or other
Responsive Pleading.

Respectfully submitted. Mandaluyong City for Tagum City,


Davao del Norte, August 16, 2016

ESTHER V. VALIENTE
Complainant

Copy furnished:

ATTY. HECTOR GERARD C. BELISARIO, MD


Hi-way, Salvacion,
8105 Panabo City, Davao del Norte

EXPLANATION

Due to considerable distances involved, as well as lack of


material time, and manpower to effect the personal service of this
Motion for Extension of Time to File Reply Affidavit, the same was
served to counsel for the Respondents through registered mail and
personally filed with the Honorable Court.

Esther V. Valiente