Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

MOTION TO LIFT ORDER OF ARREST

Accused Jasper Sol Cruz, by counsel, to the Honorable Court, most respectfully states that:

That on 20 November 2013, the Honorable Court ordered the arrest of the accused for her failure to appear during the scheduled hearing on the same date despite due notice;

With the kind indulgence of this Honorable Court, the accused did not neglect her appearance and to refuse and disobey the lawful orders of this Honorable Court. However, due to the fact that he was indisposed on the said hearing date, he failed to appear before this Honorable Court. Moreover, accused hereby undertakes to attend on the said hearing date;

The filing of this motion is not in any manner intended to delay the proceedings and early resolution of the above- captioned case but is solely for the reasons above-stated;

RELIEF

IN VIEW WHEREOF, it is respectfully prayed of this Honorable Court that the instant motion be granted and the Order of Arrest dated 20 November 2013, be lifted.

Accused prays for such other reliefs as are just and equitable under the circumstances.

Dasmarinas City, for Imus City, 13 December 2013.

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

PROSECUTOR JACK MIOF

Office of the City Prosecutor

Imus City, Cavite

CLERK OF COURT

Regional Trial Court

Branch 21, Imus City

ATTY. JEFFREY PARIL

1080 Negros Street, Balic- Balic

Sampaloc, Manila

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,

Aguinaldo Highway, Perpetual Village,

Palico III, Imus City, Cavite

G r e e t i n g s:

Please submit the foregoing Motion to Lift Order of Arrest and kind consideration of the Honorable Court immediately upon receipt hereof.

RAPHAEL ENRIQUE V. CORONADO

Copy furnished:

PROSECUTOR JACK MIOF

Office of the City Prosecutor

Imus City, Cavite

ATTY. JEFFREY PARIL

1080 Negros Street, Balic- Balic

Sampaloc, Manila

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,

Aguinaldo Highway, Perpetual Village,

Palico III, Imus City, Cavite