Republic of the Philippines

Department of Agriculture
BUREAU OF FISHERIES AND AQUATIC RESOURCES
3rd Floor, PCA Building, Elliptical Road, Diliman, Quezon City

BUREAU OF FISHERIES AND

AQUATIC RESOURCES
Complainant,

-versus- ADMINISTRATIVE CASE FOR

INSUBORDINATION

PHOEBE I. LAQUINDANUM
Respondent.
x-------------------------------------x

MOTION FOR EXTENSION OF TIME

TO FILE POSITION PAPER

COMPLAINANT, by the undersigned counsel, and unto this Honorable Office,

most respectfully states that:

1. This Honorable Office, through a Notice dated May 06, 2019, notified the
parties in the above-said administrative case the submission of their position
papers on May 14, 2019;

2. The undersigned counsel, however, anticipates his inability to file the position
paper on or before said date due to our pending request for the issuance of
authenticated copies of the attached documents in the complaint and to
secure additional documents including the testimonies of witnesses;

3. Furthermore, the undersigned counsel needs more time to study the case and
the position paper may not be aptly filed without taking due consideration of
the documents to be secured;

4. For this reason, the undersigned is constrained to ask for an extension of time
within which to submit its Position Paper;

5. This motion is not intended foe delay but is motivated only by the foregoing
circumstances.

WHEREFORE, it is respectfully prayed that the prosecution be granted an

extension of thirty (30) days from May 14, 2019, or until June 12, 2019 within which to
submit its Position Paper.

Tuguegarao City, Cagayan, Philippines; 07 May 2019.

ATTY. RODERICK N. REVILLOZA

BFAR Prosecutor
BFAR Regional Office No. 02
Government Center, Carig Sur,
Tuguegarao City, Cagayan

COPY FURNISHED:

PHOEBE I. LAQUINDANUM
Market Specialist II
Office for Special Concerns