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Sample Motion Vehicle
Sample Motion Vehicle
- versus -
CIVIL CASE NO. 2014-507-P
For: Damages
JESSA M. CRUZADO, ALLTECH
BIOTECHNOLOGY CORPORATION,
DR. DAVID MORPETH,
Defendants.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - x
Ex Abundanti Ad Cautelam
MANIFESTATION WITH
URGENT MOTION FOR RELEASE OF VEHICLE
1 Complaint dated 10 November 2014 (“Complaint”), par. 6; Annexes “A” and “A-1”.
2 Ibid., par. 8; Annexes “C” to “C-10”.
3 Id., par. 8; Annex “B”.
4 Id., par. 8; Annex “B-1”.
Vehicle, the PNP refused to release the same because it is allegedly
subject of this pending case.
4. With all due respect, the pendency of this case should not
be a reason to impound the Subject Vehicle. The Subject Vehicle
should be released to Defendant Alltech.
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owner as the same was being detained upon the mere orders of the
police – without any legal authority or basis.
11 A list of the violations found in Section 73 is attached hereto as Annex “A” and is made
an integral part hereof.
12 Edralin v. Philippine Veterans Bank, G.R. No. 168523, 9 March 2011, 645 SCRA 75, 76.
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PRAYER