Motion

REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT First Judicial Region Las Piñas, City Branch 100 PEOPLE OF THE PHILIPPINES, Plaintiff, -versus-

JUAN DELA CRUZ  Accused. x------------------------------------------------x E X - P A R T E   MOTION  MOTION

Criminal Case No. 9856 For: Reckless Imprudence Resulting to Serious Physical Injuries and Damage to Property Property

TO RELEASE BAIL

WITH DUE RESPECT, Undersigned counsel unto the Honorable Court most respectfully moves for the release of the cash bond of the late Juan Dela Cruz and for this purpose states that: 1. Undersigned 1. Undersigned counsel was then the lawyer of the late Juan Dela Cruz in the above-entitled case. 2.  2.  Mr. Juan Dela Cruz posted bail for his temporary liberty in the above-entitled case as evidenced by Official Receipt No. 4044233 B. A copy of the Order of the Honorable Court dated May 03, 2013 regarding the filing of cash bond by Mr. Juan Dela Cruz is hereto attached as Annex “A”. 3.  3.  On June 15, 2013, undersigned counsel received the Order of the Honorable Court dated June 6, 2013, hereto attached as Annex “B” , stating in part that “(t)he Information is thereby ordered WITHDRAWN”. 4.  4.  Mr. Juan Dela Cruz died on August 02, 2013. A copy of his certificate of death is hereto attached as Annex “C”.

EX-PARTE  MOTION

TO RELEASE BAIL CRIMINAL CASE NO. 9864

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4. Considering the foregoing, the release of the bail posted by the late Juan Dela Cruz is proper. Undersigned counsel undertakes to turn over any amount of bail to be released to Mrs. Luningning Dela Cruz, the wife of the late Juan Dela Cruz, or her duly authorized representative in the event that the foregoing motion will be granted by the Honorable Court. PRAYER WHEREFORE, premises considered, it is most respectfully prayed of the Honorable Court to grant the foregoing motion to release bail. Such other reliefs and remedies just and equitable under the premises are likewise prayed for. September 23, 2013, Las Piñas City, Philippines.

By:

UNCLE SAM Roll No. 12345-May 20, 2009 IBP No. 654321-Jan. 3, 2013 Las Piñas Chapter PTR No. 1234567-Jan. 10, 2013 TIN 132-456-531 MCLE Compliance No. IV-002986 May 29, 2013

With my consent: Luningning Dela Cruz (Wife of the late Juan Dela Cruz)

EX-PARTE  MOTION

TO RELEASE BAIL CRIMINAL CASE NO. 9864

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