Republic of the Philippines

Department of Justice

OFFICE OF THE CITY PROSECUTOR

________________________________________

URGENT MOTION FOR EARLY RESOLUTION

Complainant, by counsel, to the Honorable Prosecutor, respectfully states that:

1. This is a criminal action for Qualified Theft under the Revised Penal Code which was filed on 06 May 2011.

2. Since then, complainant is patiently waiting for the resolution of the above-captioned case.

3. Truth to tell, private complainant has received reliable information from unimpeachable sources that respondents are processing papers to go abroad.

4. Thus, the undersigned is requesting for the early resolution of the above-entitled case so as not frustrate the ends of justice.

WHEREFORE, it is respectfully prayed that a Resolution be rendered in this case based on the evidence presented.

Other just and equitable reliefs are likewise prayed for.

Imus City, 17 December 2012.

__________________________________

Counsel for Private Complainant

1080 Negros Street, Balic- Balic

Sampaloc, Manila

by:

__________________________________

IBP#_________, _________Chapter, _________

PTR#_________, _________, _________, _________

Attorney’s Roll No. _________

MCLE Compliance No. II- _________

MCLE Compliance No. III- _________

MCLE Compliance No. IV- _________

Copy furnished:

PROSECUTOR JACK MIOF

Office of the City Prosecutor

Imus City, Cavite

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,

Aguinaldo Highway, Perpetual Village,

Palico III, Imus City, Cavite

ATTY. RAPHAEL CORONADO

2nd Floor, RCVJ Building,

Don P. Campa Avenue, Barrio Uno,

2662 Dasmarinas City, Cavite