Motion to Suspend Arraignment (Regional Trial Court) due to pendency of Motion for Reconsideration before the Office the City Prosecutor.
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Motion to Quash
John Branca V HTWFFull description
Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT
through the undersigne undersigned d ssistant ssistant PRIV PRIVATE COMPLAI COMPLAINAI NAINT NT X, through City Prosecutor' before this -onorable Court' .ost respectfully sub.it this Motion to Set Arraignment Arraignment ' and states that)
/% 0his 0his is a cri. cri.in inal al case case for for Rape Rape 1hich 1hich 1as filed filed on 2' June June 24/5 24/5 before the office of the the City Prosecutor of Quezon City6
2% $n July July 3' 24/5 24/5'' the the -ono -onora rabl blee ssi ssist stan antt City City Pros Prosec ecut utor or John John 7o.ini 7o.inicc 0% Buhang Buhangin' in' findin finding g probab probable le cause' cause' reco..e reco..ende nded d the filing of Rape against the accused6
3% $n July ' 24/5 24/5'' the the -ono -onora rabl blee Court Court issue issued d a 9arra arrant nt of rre rrest st against accused :6
;% $n July /4' 24/5' accused 1as arrested by the Quezon City Police% -e 1as detained at Quezon City Police 7istrict -Q < Ca.p =aringal' after 1hich' said accused posted a bail for his pro+isional release6
>% Based on reliable infor.ation' accused : intends to lea+e the country for the purpose of absconding and thereby e+ading prosecution of this case6
% In +ie1 of the foregoing' pri+ate co.plainant ? 1ishes to ha+e accused : arraigned for the -onorable Court to pro.ptly ascertain the guilt of the accused%
PRAYER
9-#R#($R#' pre.ises considered' Pri+ate Co.plainant respectfully prays that the -onorable Court set the arraign.ent of ? on July 2/' 24/5' at p.' or at the earliest possible date and ti.e% ll other reliefs as are @ust and dee.ed eAuitable are also prayed for%
RESPECTFULLY SUBMITTED.
Quezon City' NCR' Philippines' July 2/' 24/5%
NICOPIOR LAW OFFICE
Counsel for Pri+ate Co.plainant 2 Batasan -ills' Quezon City