Professional Documents
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Ricamonte Demurer
Ricamonte Demurer
JD3D
ELIZA MONTMAYOR,
Complainant
CRIMINAL CASE NO. 59-0092
FOR: CONCUBINAGE
- versus -
x----------------------------------------------x
MOTION
(FOR LEAVE OF COURT TO FILE DEMURRER TO
EVIDENCE)
RAMOS, through counsel, unto the Honorable Court, most respectfully states:
1. That on June 25, 2022, accused, through the undersigned, received a copy
of the ORDER dated June 15, 2022 stating that the prosecution formally
offered their exhibits from Exhibit “A” to Exhibit “I” which have been
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SUBMITTED BY: STEPHANIE ERICA LOUISE RICAMONTE. JD3D
Rule 119 of the Rules of Court, hence, this Motion (For Leave of Court to
4. That there is dearth of evidence that accused committed the crime charged
5. That the sex scandal videos is false which resulted to no evidence admitted
that both of the accused actually committed the crime filed against them
do not confirm the allegations and is clear that is purely speculative without
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SUBMITTED BY: STEPHANIE ERICA LOUISE RICAMONTE. JD3D
7. That private complainant herself admitted that during the hearing on July
20, 2022, that she knew of Mr. Enrique’s infedelity with Ms. Ramos and
prolonging the trial of this case based on incredible and hearsay evidence
would only cause injustice and damage to both accused who is compelled
to litigate herein.
GRANTED.
By:
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SUBMITTED BY: STEPHANIE ERICA LOUISE RICAMONTE. JD3D
NOTICE
Sir / Madam:
The undersigned would like to submit the foregoing Motion (For Leave of
Court to File Demurrer to Evidence) for the consideration and approval of the
Honorable Court on July 30, 2022 at 9:00 in the morning hereof.
Thank you.
Copy furnished:
Registry Receipt:_____________
Date:______________________
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SUBMITTED BY: STEPHANIE ERICA LOUISE RICAMONTE. JD3D
EXPLANATION
Personal filing cannot be effected upon Atty. Joan Sobredo at 2nd Floor, AGT
Building Quezon Street, Iloilo due to the distance of the said address and the office
of the undersigned counsel, hence, a copy of this Motion (For Leave of Court to File
Demurrer to Evidence) is being filed upon Atty. Joan Sobredo through registered
mail with return card.