REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION OFFICE

_________________________
_________________________
Complainants,

-versus- NPS DOCKET No. ____________

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Respondent,
x - - - - - -- - - - - -- - - - - - - - -x

MOTION TO RE-OPEN
PRELIMINARY INVESTIGATION

COMES NOW respondent, unto this Honorable Court, most

respectfully states, that:

1. The undersigned movant is the respondent in this case;

2. Respondent learned last _____________ that this case had been

filed against him by the complainants and the same was already submitted
for resolution;

3. Respondent did not receive any notice from this office requiring
him to submit counter-affidavit;

4. Respondent desires that this case be re-opened to allow him to

submit counter-affidavit and counter veiling evidence;

5. Respondent has a meritorous defense and if given opportunity to

file counter-affidavit, this case may be better resolved by the Honorable
Investigating Prosecutor;

6. Attached herewith are the copies of his intended counter-affidavit;

WHEREFORE, it is most respectfully prayed that this case be re-

opened to allow respondent to submit counter-affidavit.
 -2-

RESPECTFULLY SUBMITTED.

Caloocan City, ________________

______________________
Respondent

NOTICE

THE INVESTIGATING PROSECUTOR

City Prosecutor’s Office
Caloocan City

Greetings:

Please submit this Motion to Re-open Preliminary Investigation to this

Honorable Office for consideration and approval.

______________________

SUBSCRIBED AND SWORN to before me this _____ day of

__________ at Caloocan City, Metro Manila. Affiant exhibited his ID No.
_________________________.

Doc. No. ___________

Page No. ___________
Book No. ___________
Series of 2020.
Copy Furnished:

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__________________________
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Caloocan City

EXPLANATION

Due to lack of messengerial personnel, service by registered mail was

resorted to.

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