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  • Motion For Postponement

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    Trian Lauang
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    1. Respondent Jessie Cruz, through his lawyers Ferdinand Topacio and Joselito Lomangaya, filed a motion to postpone scheduled reinvestigation dates of April 10 and 17, 2015 at the Department of Justice in Manila. 2. The lawyers will be unavailable on those dates as they have a previously booked trip out of the country from April 9-17 and a scheduled court hearing on April 17. 3. Respondent and his lawyers request that the reinvestigation dates be postponed and rescheduled to April 24, 2015, when the lawyers can guarantee their presence and availability.

    Original Description:

    Motion to Postpone

    Original Title

    Motion for Postponement

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    1. Respondent Jessie Cruz, through his lawyers Ferdinand Topacio and Joselito Lomangaya, filed a motion to postpone scheduled reinvestigation dates of April 10 and 17, 2015 at the Department of Justice in Manila. 2. The lawyers will be unavailable on those dates as they have a previously booked trip out of the country from April 9-17 and a scheduled court hearing on April 17. 3. Respondent and his lawyers request that the reinvestigation dates be postponed and rescheduled to April 24, 2015, when the lawyers can guarantee their presence and availability.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    98 views3 pages

    Motion For Postponement

    Uploaded by

    Trian Lauang
    1. Respondent Jessie Cruz, through his lawyers Ferdinand Topacio and Joselito Lomangaya, filed a motion to postpone scheduled reinvestigation dates of April 10 and 17, 2015 at the Department of Justice in Manila. 2. The lawyers will be unavailable on those dates as they have a previously booked trip out of the country from April 9-17 and a scheduled court hearing on April 17. 3. Respondent and his lawyers request that the reinvestigation dates be postponed and rescheduled to April 24, 2015, when the lawyers can guarantee their presence and availability.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as docx, pdf, or txt
    of 3

    REPUBLIC OF THE PHILIPPINES

    DEPARTMENT OF JUSTICE
    NATIONAL PROSECUTION SERVICE
    MANILA

    NBI-SHEALA MAE VITO MANALO


    Complainants,

    - versus - I.S. No.XVI-INV-09K-0777


    (Crim. Case No. 14-11785-
    M)
    For: Rape in Relation to
    JESSIE CRUZ RA 7610
    Respondent.
    x--------------------------------------------x

    MOTION FOR POSTPONEMENT


    Respondent JESSIE CRUZ, through undersigned counsel
    respectfully states:

    1. On 06 April 2015, undersigned counsel received a


    Subpoena dated 20 March 2015 directing Respondent Jessie
    Cruz to appear for a scheduled re-investigation of the above-
    captioned case on 10 April 2015 and 17 April 2015 at ten in
    the morning (10:00 a.m.), at the Department of Justice, Padre
    Faura, Manila.

    2. Unfortunately due to unforeseen circumstances


    undersigned counsels Attys. Ferdinand S. Topacio and
    Joselito O. Lomangaya would be unavaible on on both dates:
    Both counsels have a previously booked trip to
    _____________ from 09 April to ___ April 2015 (copies of
    counsels airplane e-tickets are hereto attached as Annexes
    “A” and “B”) ; and a previously re-scheduled hearing for
    _______________ in ___________ on 17 April 2010.

    3. Therefore, there being no other counsel available to


    represent Respondent, Respondent and undersigned
    counsels, begs the kind indulgence of the Honorable
    Prosecutor that the previously set hearings be postponed and
    reset on 24 April 2015 wherein said counsels guarantee their
    presence and availability.
    4. This motion is not intended for delay but is motivated
    solely for the foregoing reason.

    PRAYER

    WHEREFORE, Respondent and undersigned counsel


    respectfully pray that this Honorable Office postpone the
    previously set dates for the reinvestigation of the above-captioned
    case on 10 April 2015 and 17 April 2015, to 24 April 2015.

    Respondent further prays for such other reliefs and remedies


    just and equitable under the premises.

    Pasig City for Manila, 08 April 2015.

    TOPLAW
    TOPACIO LAW OFFICE
    Counsel for the Accused
    Suite 107 Skyway Twin Towers,
    H. Javier St., Ortigas Center
    Pasig City, Metro Manila
    Telephone Number (+632)5710270
    Fax Number (+632)5711626
    Email address: [email protected]

    By:

    FERDINAND S. TOPACIO
    Attorney’s Roll No. 38271
    IBP Lifetime Membership No. 562537
    PTR. No. 3651073/01. 02. 2014/ Cavite City
    MCLE Compliance No. IV-0015379
    Issued on 03 April 2013

    JOSELITO O. LOMANGAYA
    Attorney’s Roll No. 47328
    IBP O.R. No.0992336/ 01.22.15/ Makati City
    PTR No. 2361838 / 01.22.15/ Mandaluyong
    MCLE Compliance No. IV-0015382
    Issued on 03 April 2013

    COPY FURNISHED (via registered mail)


    ATTY. ERNESTO A. IMBAG
    Counsel for Complainant
    Unit 23 Starmall Apartelle
    EDSA-Shaw Boulevard
    Mandaluyong City

    SHEALA MAE VITO MANALO


    Complainant
    Sitio Cabading, Brgy. San Jose
    Antipolo City

    DEPARTMENT OF JUSTICE
    Padre Faura, Manila

    OFFICE OF THE PROSECUTOR


    Morong, Rizal

    EXPLANATION

    The foregoing was filed and served via registered mail due
    to distance and time constraints. Please disregard if served
    personally.

    JOSELITO O. LOMANGAYA

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