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  • Motion For Leave To File Rejoinder With Rejoinder

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    Hiero Phant
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    This document is a motion filed in a municipal trial court requesting leave to file a motion for reinvestigation. It summarizes that the accused recently received notice of probable cause finding and arrest warrant but has not received a copy of the information filed against them. The accused asserts the probable cause finding was made with undue haste without allowing them to explain their side. The motion requests the court grant leave to file the motion for reinvestigation and grant the motion for reinvestigation. It seeks to exclude certain exhibits and testimonies from the record.

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    Motion for Leave to File Rejoinder with Rejoinder

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    This document is a motion filed in a municipal trial court requesting leave to file a motion for reinvestigation. It summarizes that the accused recently received notice of probable cause finding and arrest warrant but has not received a copy of the information filed against them. The accused asserts the probable cause finding was made with undue haste without allowing them to explain their side. The motion requests the court grant leave to file the motion for reinvestigation and grant the motion for reinvestigation. It seeks to exclude certain exhibits and testimonies from the record.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    415 views2 pages

    Motion For Leave To File Rejoinder With Rejoinder

    Uploaded by

    Hiero Phant
    This document is a motion filed in a municipal trial court requesting leave to file a motion for reinvestigation. It summarizes that the accused recently received notice of probable cause finding and arrest warrant but has not received a copy of the information filed against them. The accused asserts the probable cause finding was made with undue haste without allowing them to explain their side. The motion requests the court grant leave to file the motion for reinvestigation and grant the motion for reinvestigation. It seeks to exclude certain exhibits and testimonies from the record.

    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 2

    REPUBLIC OF THE PHILIPPINES

    MUNICIPAL TRIAL COURT


    ____________
    BRANCH __, CITY OF ____________

    PEOPLE OF THE PHILIPPINES,


    Plaintiff,

    - versus - _______________________
    For: RECKLESS
    IMRPUDENCE RESULTING
    TO HOMICIDE and
    Accused. DAMAGE TO PROPERTY
    (Violation of Art. 365, RPC)

    X-----------------------------------------------------------------------------------------X

    MOTION FOR LEAVE TO FILE


    MOTION FOR REINVESTIGATION

    and

    MOTION FOR REINVESTIGATION

    Accused, by counsel, respectfully states:

    1. On __ June 2020, Accused received a copy of the Resolution


    dated 10 March 2020 of the Office of the Provincial Prosecutor of Capiz
    (“OPP-Capiz”), finding probable cause to charge him of the subject offense.

    2. On __ June 2020, Accused was informed that there was an


    arrest warrant for him. He then inquired with ____ explain. Accused has not
    yet received a copy of the Information filed against him.

    3. On 21 June 2020, Accused was arrested ____ narrate.

    4. With all due respect, the Accused asserts that the Resolution of
    OPP-Capiz was issued with undue haste, leaving the Accused no time to
    explain his side, and without basis, as will be shown.

    5. The Accused, thus, respectfully moves for leave from this


    Honorable Court to file his Motion for Reinvestigation, incorporated
    hereunder.
    2

    MOTION FOR REINVESTIGATION

    1. In its Reply, MicroEnsure claimed that BAC’s Opposition to its


    Motion to Admit Commissioner is bereft of merit because it is premature
    and a rehash of BAC’s Motion to Dismiss Counterclaims.

    2. MicroEnsure is raising claims which should undisputedly be


    referred to arbitration, thus confusing the issues, and resultantly delaying
    the proceedings.
    3. In closing, BAC would like to emphasize before this Honorable
    Court that to date, MicroEnsure has not filed any notice to arbitrate
    regarding its pre- and post-Yolanda, and non-calamity insurance claims.

    RELIEF

    WHEREFORE, it is respectfully prayed that this Honorable Court:

    1. Grant the Accused leave to file his Motion for Reconsideration;

    2. Grant the Accused’s Motion for Reinvestigation; and

    3. EXCLUDE from the records of this case, Exhibits “42” to “47,


    “49” to “49-ff”, the testimonies
    Other reliefs, just and equitable under the premises, are likewise
    prayed for.

    Respectfully submitted.

    Makati City for City of Manila, 5 November 2018.

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