Republic of the Philippines

REGIONAL TRIAL COURT

_______ JUDICIAL REGION
Branch ____
_______________

PEOPLE OF THE PHILIPPINES,

Plaintiff, Crim. Case No. 1245
For: Violation of RA 9165

-versus-

XXX,
Accused.
x----------------------------------------x

URGENT EX PARTE MOTION FOR THE IMMEDIATE

RELEASE OF THE ACCUSED
Accused-Movant, assisted by the undersigned counsel, unto this
Honorable court most respectfully state as follows:

1. That in the order of the Honorable court dated 3 December 2021, the
terms and conditions of the Order of Probation GRANTED to the
accused were read and explained to him in the Filipino language
which he speaks and understands.

2. That accused however is still languishing in jail at BJMP detention

facility _________.

3. That in order for the accused to appear before the probation office and
finally begin his probation and comply with each and every condition
therein imposed, his immediate release from confinement is but
imperative. His continued incarceration after the promulgation of
probation has no more basis or ground

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

the Honorable Court to grant the instant Motion and thus issue an Order
directing the BJMP of __________ to immediately release from their
custody xxx.

Other reliefs just and equitable in the premises are likewise sought.

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