Motion to Release Motor Vehicle

REPUBLIC OF THE PHILIPPINES DEPARTMENT OF JUSTICE OFFICE OF THE CITY PROSECUTOR ANGELES CITY CHRISTINE MAE PELAEZ y VERNA, NPS DOC. NO. INQ-16E-00375 Complainant, -versusEDWARD REYES y SANTOS, JASPER GARCIA y VITAL & GLEN CURA y LARA Respondent. x---------------------------------------------X MOTION TO RELEASE MOTOR VEHICLE Comes Now, movant RACHELLE JOY SANTOS REYES, unto this Honorable Court, most respectfully state that: Movant is the absolute and registered owner of a Tricycle with Plate No. ____________, and more particularly described as follows, to wit: Make: Mitsukoshi Series: Daan Hari Engine No: 161 FMJE 2312165 Chassis No: ________________ as evidenced by the O. R and C.R hereto attached as Annezes “A” and “B” hereof; That the above motor vehicle is presently impounded at the Angeles City Police Station 6 by virtue of the filing of the above case; The movant moves for the release of the same as she is using the same as her personal service in her day to day activities; That movant is willing to substitute the same with a photocopy of its Certificate of Registration and Official Receipt, together with a copy of its photographs; This motion is filed in the interest of justice; WHEREFORE, it is most respectfully prayed unto this Honorable Office that the foregoing motion be granted. Angeles City, May 16, 2016. RACHELLE JOY SANTOS REYES Complainant