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    Motion For Issuance of A Hold Departure Order: Regional Trial Court

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    Gracelle Mae Oraller
    This document is a "Motion for Issuance of a Hold Departure Order" filed in a criminal case for Qualified Theft against the accused. The private complainant believes the accused intends to leave the country to evade prosecution and requests the court issue an order directing immigration to place the accused on a hold departure list. Personal details of the accused such as name, sex, address, and photograph are provided to assist with identification. The motion will be heard on August 23, 2011 at 8:30am.

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    Motion For Issuance of A Hold Departure Order: Regional Trial Court

    Uploaded by

    Gracelle Mae Oraller
    673 views4 pages
    This document is a "Motion for Issuance of a Hold Departure Order" filed in a criminal case for Qualified Theft against the accused. The private complainant believes the accused intends to leave the country to evade prosecution and requests the court issue an order directing immigration to place the accused on a hold departure list. Personal details of the accused such as name, sex, address, and photograph are provided to assist with identification. The motion will be heard on August 23, 2011 at 8:30am.

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    This document is a "Motion for Issuance of a Hold Departure Order" filed in a criminal case for Qualified Theft against the accused. The private complainant believes the accused intends to leave the country to evade prosecution and requests the court issue an order directing immigration to place the accused on a hold departure list. Personal details of the accused such as name, sex, address, and photograph are provided to assist with identification. The motion will be heard on August 23, 2011 at 8:30am.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    673 views4 pages

    Motion For Issuance of A Hold Departure Order: Regional Trial Court

    Uploaded by

    Gracelle Mae Oraller
    This document is a "Motion for Issuance of a Hold Departure Order" filed in a criminal case for Qualified Theft against the accused. The private complainant believes the accused intends to leave the country to evade prosecution and requests the court issue an order directing immigration to place the accused on a hold departure list. Personal details of the accused such as name, sex, address, and photograph are provided to assist with identification. The motion will be heard on August 23, 2011 at 8:30am.

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    © All Rights Reserved
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    The document discusses a motion for a hold departure order against an accused in a criminal case for qualified theft.

    The criminal case is for qualified theft under the Revised Penal Code against the accused.

    The accused's name is redacted in the document.

    Republic of the Philippines

    REGIONAL TRIAL COURT


    8th Judicial Region
    BRANCH 9
    Tacloban City

    REPUBLIC OF THE PHILIPPINES,

    Complainant,

    -versus-

    ______________________,

    Accused.

    x - - - - - - - - - - - - - - - - - - - - - - - - -x

    CRIMINAL CASE NO. _______________

    FOR: _________________

    MOTION FOR ISSUANCE OF A HOLD


    DEPARTURE ORDER

    Private Complainant, by counsel, under the direct control and supervision of the
    Honorable Public Prosecutor respectfully alleges that:

    This is a criminal complaint for Qualified Theft under the Revised Penal Code
    against the accused.

    Private complainant has reliable information that said accused is intending to go


    abroad to evade criminal prosecution.

    Consequently, to insure that accused do not leave the country to evade criminal
    prosecution and to guarantee that he is properly brought before the bar of justice to
    face his charge, it becomes imperative that he be placed in the “hold departure
    order” list of the Bureau;

    For the guidance and information of the Court, we furnish the complete data,
    regarding accused ________________________________ to wit;
    Complete Name :
    Sex :

    Civil Status :

    Complete Address :

    Date of Birth :

    Birthplace :

    Age :
    ________________________________

    ________________________________

    ________________________________

    ________________________________

    ________________________________

    ________________________________

    ________________________________
    Photocopy of the photograph of the ________________________________ is
    hereto attached as Annex “A” for easy reference.

    WHEREFORE, premises considered, it is respectfully prayed that this Honorable


    Court issue an order directing the Commissioner of the Bureau of Immigration to
    place accused ________________________________ in their “Hold Departure
    Order” list.

    Other relief and remedies just and equitable under the premises are prayed for.

    City of Manila, for Imus City, 25 July 2011.

    PARIL LAW OFFICE

    Counsel for Private Complainant

    1080 Negros Street, Balic- Balic

    Sampaloc, Manila

    by:

    JEFFREY PARIL

    IBP#__________, __________Chapter, __________

    PTR#__________, __________, __________, __________

    Attorney’s Roll No. __________

    MCLE Compliance No. II- __________


    MCLE Compliance No. III- __________

    MCLE Compliance No. IV- __________

    With my conformity and

    Under my control and supervision:

    PROSECUTOR JACK MIOF

    Asst. City Prosecutor

    Notice
    Office of the City Prosecutor

    Imus City, Cavite

    CLERK OF COURT

    Regional Trial Court

    Branch 21, Imus City

    ATTY. RAPHAEL CORONADO

    2nd Floor, RCVJ Building,

    Don P. Campa Avenue, Barrio Uno,

    2662 Dasmarinas City, Cavite

    ATTY. ALEXANDER LIQUIGAN

    Unit 3C, De Quiroz Bldg.,

    Aguinaldo Highway, Perpetual Village,

    Palico III, Imus City, Cavite

    Greetings:

    Please be notified the undersigned has requested the Branch Clerk of Court to
    include the foregoing Motion in the Court Calendar on August 23, 2011 at 8:30 a.m.
    that counsel and matter may be heard.

    JEFFREY PARIL

    Copy furnished:

    Office of the City Prosecutor


    Imus City, Cavite

    ATTY. RAPHAEL CORONADO

    2nd Floor, RCVJ Building,

    Don P. Campa Avenue, Barrio Uno,

    2662 Dasmarinas City, Cavite

    ATTY. ALEXANDER LIQUIGAN

    Unit 3C, De Quiroz Bldg.,

    Aguinaldo Highway, Perpetual Village,

    Palico III, Imus City, Cavite

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