REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
_________ CITY, BRANCH ___

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Crim. Case No. ____________

For: Qualified Theft Through
Falsification of Commercial
Documents

JOHN DOE,
Accused.
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URGENT MOTION FOR RECONSIDERATION

(RE: FORFEITURE OF CASH BOND AND
ISSUANCE OF WARRANT OF ARREST)

Accused JOHN DOE, respectfully states:

1. On August 15, 2019, accused went to the court for his

arraignment and pre-trial conference. However, accused overlooked
that the case was set for arraignment and pre-trial conference on
August 14, 2019, at 2:00 P.M. per Order of Release dated July 15,
2019.

2. Accused sincerely apologizes to the Honorable Court and

to the other parties for his non-appearance on the scheduled hearing
due to an honest mistake. Accused did not intend to disregard the
order of the court and to cause any inconvenience to all parties.

3. Moreover, accused is still in search for his counsel of choice

to enable him to prepare for his defense.

4. Thus, accused respectfully moves that the Honorable Court

RECONSIDER and SET ASIDE its order of forfeiture of his cash
bond and the issuance of warrant of arrest of the accused. Accused
respectfully moves also for the setting of the arraignment and pre-
trial conference on a date and time convenient to the court’s
calendar.

1
 RELIEF

Accused respectfully prays that the Honorable Court (1)

RECONSIDER and SET ASIDE its order of forfeiture of his cash
bond and the issuance of warrant of arrest of the accused, (2)
ORDER the setting of the arraignment and pre-trial conference on a
date and time convenient to the court’s calendar, and (3) GRANT
accused other equitable relief.

Accused

NOTICE OF HEARING

THE CLERK OF COURT

Regional Trial Court, Branch

Ladies and Gentlemen:

Please take notice that this motion will be submitted for the
consideration and approval of the Honorable Court on August 22,
2019 at 2:00 p.m.

COPY FURNISHED:

EXPLANATION ON MODE OF SERVICE

This motion will be served to private complainant by

registered mail because of constraints in time, distance, and
manpower, making personal service impracticable. An extra copy will
be served by private courier.