Motion To Admit
Motion To Admit
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MOTION TO ADMIT
ACCUSED, through counsel and unto this Honorable Court, most
respectfully states that:
3. The accused had fifteen (15) days from the promulgation of the
decision or until March 2, 2020 to file an Application for Probation.
6. The delay of one (1) day in the filing of the Application for Probation
is not intended to undermine the speedy and proper administration of
justice. The reason for the delay was beyond the control of the
accused and the undersigned counsel.
8. The accused is asking for compassion and is hoping that a mere one
(1) day delay would merit the consideration of the Honorable Court.
PRAYER
Accused prays for such other reliefs that are just and equitable under
the premises.
Sgd.
ATTY. STEPHANIE M. SANTOALLA
Counsel for the Accused
IBP NO. 071717, 12/12/19, Davao City
PTR NO. 071717, 12/12/19, Davao City
ROLL ATTORNEY NO. 11077
MCLE Comp. No. IV-0004785, 3/2/19
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Copy Furnished: (Personal Service)
Sgd.
ARTURO A. MILITAR
Lot 6, BLk18, Phase 8A
Deca Homes, Mintal, Davao City
Sgd.
ATTY. JACOBO C. MONDRAGON
2/F, Door 6, ABC Building
Damosa Complex, Lanang
Davao City