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    Motion To Defer Proceedings

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    ERICKSKIE23
    Jack Anino filed a manifestation with an urgent motion to hold in abeyance the proceedings for the resolution of the motion to withdraw information filed by the City Prosecutor. Anino received a resolution from the City Prosecutor dated February 13, 2020 and intends to file a motion for reconsideration of that resolution within 15 days. Anino is requesting the court to hold proceedings in abeyance pending resolution of Anino's motion for reconsideration, which challenges the City Prosecutor's resolution. Anino asserts this motion is not filed for delay but to protect his right to challenge the City Prosecutor's resolution through a reconsideration motion.

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    Motion To Defer Proceedings

    Uploaded by

    ERICKSKIE23
    769 views3 pages
    Jack Anino filed a manifestation with an urgent motion to hold in abeyance the proceedings for the resolution of the motion to withdraw information filed by the City Prosecutor. Anino received a resolution from the City Prosecutor dated February 13, 2020 and intends to file a motion for reconsideration of that resolution within 15 days. Anino is requesting the court to hold proceedings in abeyance pending resolution of Anino's motion for reconsideration, which challenges the City Prosecutor's resolution. Anino asserts this motion is not filed for delay but to protect his right to challenge the City Prosecutor's resolution through a reconsideration motion.

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    Sample Motion to Defer Proceedings for Legal Forms

    Original Title

    Motion to Defer Proceedings

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    Jack Anino filed a manifestation with an urgent motion to hold in abeyance the proceedings for the resolution of the motion to withdraw information filed by the City Prosecutor. Anino received a resolution from the City Prosecutor dated February 13, 2020 and intends to file a motion for reconsideration of that resolution within 15 days. Anino is requesting the court to hold proceedings in abeyance pending resolution of Anino's motion for reconsideration, which challenges the City Prosecutor's resolution. Anino asserts this motion is not filed for delay but to protect his right to challenge the City Prosecutor's resolution through a reconsideration motion.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    769 views3 pages

    Motion To Defer Proceedings

    Uploaded by

    ERICKSKIE23
    Jack Anino filed a manifestation with an urgent motion to hold in abeyance the proceedings for the resolution of the motion to withdraw information filed by the City Prosecutor. Anino received a resolution from the City Prosecutor dated February 13, 2020 and intends to file a motion for reconsideration of that resolution within 15 days. Anino is requesting the court to hold proceedings in abeyance pending resolution of Anino's motion for reconsideration, which challenges the City Prosecutor's resolution. Anino asserts this motion is not filed for delay but to protect his right to challenge the City Prosecutor's resolution through a reconsideration motion.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
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    of 3

    Republic of the Philippines

    Municipal Trial Court in Cities


    11th Judicial Region, Branch 6
    Davao City

    PEOPLE OF THE Crim. Case No.:


    PHILIPPINES, R-DVO-19-00994-PR
    Plaintiff,

    -versus- For:
    SERIOUS PHYSICAL INJURY
    LEO B. ESCALANTE JR.,
    Respondent.
    x--------------------------------------x

    MANIFESTATION WITH VERY URGENT MOTION


    TO HOLD IN ABEYANCE PROCEEDINGS

    COMES NOW, Private Complainant, unto this Honorable Court,


    most respectfully manifests and moves that:

    1. The Private Complainant, Jack Anino, received a copy of the


    Resolution dated February 13, 2020 issued by Senior Assistant City
    Prosecutor Rody Duterti last February 24, 2020.

    2. Attached to the said Resolution is a Motion dated February 13,


    2020 addressed to this Honorable Court for the Withdrawal of the
    Information filed against herein accused, Leo B. Escalante Jr..

    3. Private Complainant respectfully manifests that he intends to


    file a Motion for Reconsideration of the Resolution dated February 13, 2020
    within fifteen (15) days from its receipt. Private Complainant has until
    February 28, 2020 within which to file his Motion for Reconsideration.

    4. In lieu of Private Complainant’s intention to file a motion for


    the reconsideration of the subject resolution, Private Complainant, therefore,
    respectfully moves for this Honorable Court to hold in abeyance proceedings
    for the Resolution of Motion to Withdraw Information filed by the City
    Prosecutor pending resolution of the motion to be filed by the Private
    Complainant.

    5. This manifestation and motion is not interposed for delay but is


    solely grounded on the foregoing.

    WHEREFORE, premises considered, it is most respectfully prayed


    for that the proceedings for resolution of the Motion to Withdraw
    Information be held in abeyance to give way to the right of Mr. Jack Anino
    to file his Motion for Reconsideration assailing the Resolution dated
    February 13, 2020 of the Office of the City Prosecutor. Other reliefs and
    remedies just and equitable are likewise prayed for.

    RESPECTFULLY SUBMITTED.

    Davao City, March 14, 2020.

    (SGD) JACK ANINO


    Private Complainant

    NOTICE OF HEARING

    Atty. Salvador Pandesal


    The Branch Clerk of Court
    MTCC - Branch 6, Davao City

    Sir/Madam:

    Immediately upon receipt hereof, please submit the foregoing to the


    attention of the Honorable Court for its kind consideration and approval. It is
    further requested that the foregoing motion be deemed as submitted for
    resolution without need of setting the same for a hearing due to its non-
    litigious nature.

    Thank you very much.

    (SGD) JACK ANINO

    COPY FURNISHED:
    Rody Duterti Personal Service
    Senior Assistant City Prosecutor
    OFFICE OF THE CITY PROSECUTOR

    Julie Escalante Davao City Post Office


    No. 5 Pine Subd., Davao City Registry Receipt No. PY21394
    Date: March 4, 2020

    EXPLANATION
    (please disregard if served by personal service)

    Due to lack of available office/messengerial personnel, and time


    constraints, service by registered mail of this motion on the other parties
    aforementioned were resorted to.
    (SGD) JACK ANINO

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