REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

NATIONAL CAPITAL REGION
PASIG CITY BRANCH

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Crim. Case No.

versus For: Viol. Of BP 22 (9 counts)

Accused.
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URGENT AND EX-PARTE MOTION

(TO SET ASIDE ORDER AND LIFT WARRANT OF ARREST)
with
ENTRY OF APPEARANCE

Accused, by and through the undersigned counsel, to this Honorable

Court, most respectfully avers that:

1. The undersigned counsel submits his entry of appearance as

counsel de parte of accused , hence, it is requested that the undersigned

be furnished with all notices, copies and other processes and pleadings in

this case;

2. On November 20, 2004, a Warrant of Arrest was served upon

the accused, and the same posted bail for his provisional liberty, which had

been granted through an Order of Release1 dated issued by Hon. Judge,

presiding judge of the Regional Trial Court of Marikina City Branch;

1
Annex “1”
 3. When this case was set for arraignment on June 17, 2004, the

accused was not able to appear because he did not receive any notice of

arraignment;

4. It was thereafter learned that a bench warrant was issued by this

Honorable Court;

5. It is not the intention of the accused to delay the proceedings of

this case.

PRAYER

WHEREFORE, PREMISES CONSIDERED, in the highest interest

of justice, equity, and fair play, herein accused most respectfully pray of this

Honorable Court that the Order dated be set aside and the warrant of arrest

be lifted accordingly.

Accused further prays for such other measures of relief as are just and

equitable under the premises.

Quezon City for Pasig City.

LAW OFFICE
Counsel for the Accused
For the Firm:

Copy furnished:

PASIG CITY PROSECUTOR OFFICE

Pasig City Hall, Pasig City