Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

OMNIBUS MOTION FOR PRELIMINARY INVESTIGATION WITH MOTION TO DEFER ARRAIGNMENT AND TO SUSPEND PROCEEDINGS

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

1. That the instant case was file by virtue of an Inquest Proceedings conducted by Inquest Prosecutor __________________________ on ____________ _____, 20____;

2. That the herein accused failed to submit any counter affidavit or any controverting evidence in his behalf;

3. That the accused believes that if he will be given an opportunity to answer the charges against him, the resolution could have been different;

4. That the accused most respectfully prays that a preliminary investigation for the instant cases be conducted before the Office of the Provincial Prosecutor;

5. That this motion is not intended for delay but solely for the above-mentioned grounds.

WHEREFORE, premises considered, and in the interest of substantial justice it is humbly prayed that the instant Motion be granted and the records of the instant case be transmitted to the Office of the Provincial Prosecutor for the conduct of Preliminary Investigation. Movant further prays for the deferment of the arraignment and for the suspension of proceedings pending resolution of preliminary investigation.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

26 February 2014

City of Makati.

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- __________

Notice of Hearing

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 submit the foregoing motion for consideration and approval of the Honorable Court on August 1, 2011 at 8:30 a.m. or at such time and date as may be convenient to the Honorable Court.

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

The foregoing motion is being filed to the Honorable Court with copy therefore furnished to the Office of the Provincial Prosecutor and to the other party by registered mails, due to the distance of the undersigned from the said office and other party, making personal service thereof not practicable.

JEFFREY PARIL