Republic of the Philippines

OFFICE OF THE OMBUDSMAN

Preliminary Investigation and Administrative Adjudication Bureau (OIAB)-E
Agham Road, Diliman, Quezon City 1104

FIELD INVESTIGATION UNIT,

OMB-C-C-17-0132
OMBUDSMAN-MINDANAO,
(Criminal Case)
Complainant, For: Malversation of
Public Funds or
Property, Violation of
Section 3(e)
- Versus-

BERNARDO FANTIN PIOL, JR., ET AL.,

Respondents,
x------------------------------------------------x

NOTICE OF ENTRY OF APPEARANCE with

MOTION FOR EXTENSION OF TIME TO FILE
COUNTER-AFFIDAVIT

COMES NOW, respondent, through the undersigned

counsel, unto this Honorable Office, most respectfully states
that:

1. The undersigned respectfully enters his appearance as

counsel for respondent EDGARDO B. LINSAG and
requests that from hereon, he be furnished with copies of
all pertinent documents relative to the instant case;

2. Respondent Edgardo Linsag has been charged with

Malversation of Public Funds under Article 217 of the
Revised Penal Code, violation of the Anti-Graft and
Corrupt Practices Act and administrative cases for Grave
Misconduct, Gross Negligence and Conduct Prejudicial to
the best interest of the service.

3. It is respectfully requested that all pleadings, orders and

other notices of this Honorable Court be sent to the
following address: Phase 4, Block 11, Lot 23, Ciudad
de Esperanza, Cabantian, Buhangin, Davao City.
 4. The respondent received the complaint-affidavit last
September 8, 2017, directing him to file a counter-
affidavit within ten (10) days from receipt thereof.

5. The complaint-affidavit alone is composed of sixty-six

(66) pages. The annexes attached to the complaint are
composed of voluminous records packed in several
folders.

6. As such, undersigned counsel is constrained to request

for an additional period of fifteen (15) days from the end
of the initial ten (10) days period to file counter-affidavit.

7. This motion is not intended for delay but solely due to

the foregoing reasons.

PRAYER

WHEREFORE, plaintiff most respectfully prays that the

Honorable Office take notice of this Entry of Appearance and
that all pleadings, orders and notices be sent to the above-
indicated address.

Further, it is also prayed herein that the respondent be

given an additional 15 day period from the end of the initial 10
day period to file the counter-affidavit, or until October 3,
2017.

Other reliefs, just and equitable, are likewise prayed for.

DONE this 14th day of, 2017, in the City of Davao, (for
Quezon City) Philippines.

ATTY. GAVINO M. QUIBO JR.

Counsel for Respondent
Roll No. 67033
IBP No. 005789, 05/19/2017, Davao Oriental, Philippines
PTR No. 8813336, 06/02/2017, Davao City
Admitted to the BAR: May 2017
Contact No: 09157746189
Email Address: gjquibo@gmail.com
Copy Furnished:

FIELD INVESTIGATION UNIT

OFFICE OF THE OMBUDSMAN FOR MINDANAO
4/f H&C Building, Alvarez Street,
Sta. Ana, Davao City

EXPLANATION

(please disregard this explanation if service is effected through personal

service)

Copies of this MOTION were served to the OFFICE OF THE

OMBUDSMAN and FIELD INVESTIGATION UNIT through registered
mail due to distance, time constraints, and lack of personnel to effect
personal service.

ATTY. GAVINO M. QUIBO JR.

name