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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES
11
th
Judicial Region
Branch 6
Davao City

THE PEOPLE OF THE PHILIPPINES,

CRIM. CASE NO. 149,171-F-2014

FOR: RECKLESS IMPRUDENCE
- versus -

BHENCH UDIN CASILEN
Accused.
x ------------------------------------------------x

NOTICE OF ENTRY OF APPEARANCE
WITH MOTION FOR ISSUANCE OF HOLD DEPARTURE ORDER

The undersigned counsel most respectfully:
1. Enters her appearance as the Private Prosecutor in the abovecaptioned case
for the Private Complainant;

2. Henceforth, all notices, orders, summons and other court processes of this
Honorable Court, including all pleadings, motions and other papers relative to
the abovecaptioned case be furnished and/or served upon the address of the
undersigned counsel indicated hereunder;

3. In a Notice of Arraignment and Plea dated 14 April 2014, this Honorable
Court set the Arraignment of the Accused on 30 May 2014 at 8:30 am.
However, it has come to the knowledge of the Private Complainant that the
Accused is set to depart from the Philippines for an employment opportunity
abroad;

4. Hence, the Private Complainant now moves that a Hold Departure Order be
issued against the Accused to prevent the latter from delaying the
proceedings of this instant case;


PRAYER
WHEREFORE, it is most respectfully prayed of this Honorable Court that a Hold
Departure Order be issued against the Accused to prevent him from going abroad and
further delaying the proceedings of this instant case.
RESPECTFULLY SUBMITTED.
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___________2014, Davao City, Philippines.


DORIA LAW FIRM
Room M-2, Mezzanine Floor
Valgosons Building, City Hall Drive,
Davao City

By:
ATTY. JOANNE MARIE A. COMA
Counsel for the Private Complainant
PTR No. 3630939 1/9/14
IBP No. 948631 1/9/14
Roll No. 61851
MCLE Compliance Certificate
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Copy served personally to:

BHENCH U. CASILEN
Prk. 16, Buhisan, Tibungco, Davao City


NOTICE OF HEARING

THE CLERK OF COURT
MTCC
BRANCH 6

BHENCH U. CASILEN
Prk. 16, Buhisan, Tibungco, Davao City

CITY PROSECUTOR
CITY PROSECUTORS OFFICE

Please be advised that the undersigned counsel will submit the foregoing
Notice of Entry with Motion for Issuance of Hold Departure Order for the
consideration and approval of the Honorable Court on 9 May 2014 at 8:30 am.


ATTY. JOANNE MARIE A. COMA


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Recently been admitted to the Bar on April 25, 2013