Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

EX PARTE MOTION TO RELEASE BAIL

Accused, through the undersigned counsel, unto this Honorable Court, respectfully states:

1. That accused posted bail for his provisional liberty in the above-entitled case as evidenced by Official Receipt No. 222224, dated March 4, 2011, a copy of which is hereto attached as Annex “A” and made an integral part hereof;

2. That in the Judgment of the Honorable Court promulgated on July 24, 2013, the accused was acquitted of all charges and liabilities;

3. However, the said Judgment failed to provide for the release of the bail bond posted by the accused.

WHEREFORE, in view of the foregoing, accused most respectfully prays that his cash bail bond be released.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

15 August 2013

City of Makati.

ATTY. BEN TONG

Counsel for the Accused

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MeTC - Branch 67

Makati City

Greetings!

Being a non-litigated motion, please submit the foregoing motion for consideration and approval of this Honorable Court immediately upon receipt hereof.

BEN TONG