Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

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;

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

Explanation

Copy of the Motion was furnished to the respondent by private courier due to the distance of the undersigned from the said parties, making personal service thereof not practicable.

JEFFREY PARIL