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    Motion For Issuance of Hold Departure Order

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    ERICKSKIE23
    1) The plaintiff filed an urgent motion requesting the court issue a Hold Departure Order against the accused Leo B. Escalante Jr. who is currently employed by the Philippine National Police and charged with homicide. 2) The motion cites that a memorandum was issued reinstating the accused to his prior duty station until resolution of the case, and the accused has submitted a P600,000 bail bond. 3) A Watch List Order has also been issued against the accused by the Department of Justice to prevent him from leaving the country given the serious criminal charge. 4) The motion will be submitted to the court for consideration and approval on March 25, 2020.

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    Motion For Issuance of Hold Departure Order

    Uploaded by

    ERICKSKIE23
    4K views3 pages
    1) The plaintiff filed an urgent motion requesting the court issue a Hold Departure Order against the accused Leo B. Escalante Jr. who is currently employed by the Philippine National Police and charged with homicide. 2) The motion cites that a memorandum was issued reinstating the accused to his prior duty station until resolution of the case, and the accused has submitted a P600,000 bail bond. 3) A Watch List Order has also been issued against the accused by the Department of Justice to prevent him from leaving the country given the serious criminal charge. 4) The motion will be submitted to the court for consideration and approval on March 25, 2020.

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    Sample Motion for Issuance of Hold Departure Order

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    Motion for Issuance of Hold Departure Order

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    1) The plaintiff filed an urgent motion requesting the court issue a Hold Departure Order against the accused Leo B. Escalante Jr. who is currently employed by the Philippine National Police and charged with homicide. 2) The motion cites that a memorandum was issued reinstating the accused to his prior duty station until resolution of the case, and the accused has submitted a P600,000 bail bond. 3) A Watch List Order has also been issued against the accused by the Department of Justice to prevent him from leaving the country given the serious criminal charge. 4) The motion will be submitted to the court for consideration and approval on March 25, 2020.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    4K views3 pages

    Motion For Issuance of Hold Departure Order

    Uploaded by

    ERICKSKIE23
    1) The plaintiff filed an urgent motion requesting the court issue a Hold Departure Order against the accused Leo B. Escalante Jr. who is currently employed by the Philippine National Police and charged with homicide. 2) The motion cites that a memorandum was issued reinstating the accused to his prior duty station until resolution of the case, and the accused has submitted a P600,000 bail bond. 3) A Watch List Order has also been issued against the accused by the Department of Justice to prevent him from leaving the country given the serious criminal charge. 4) The motion will be submitted to the court for consideration and approval on March 25, 2020.

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    Republic of the Philippines

    REGIONAL TRIAL COURT


    11th JUDICIAL REGION
    Branch 15
    Davao City

    People of the Philippines, Criminal Case No. 1234567


    Plaintiff

    ~ versus ~ For: HOMICIDE

    SPO1 Leo B. Escalante Jr., et. al.


    Accused

    x-------------------------------------------------x

    URGENT MOTION
    FOR ISSUANCE OF HOLD DEPARTURE ORDER

    COMES NOW, the plaintiff, by the undersigned private counsel, with the
    conformity of the public prosecutor and unto this Honorable Court,
    respectfully moves for the issuance of a Hold Departure Order (HDO)
    against the accused, and alleges that:

    1. The accused is currently employed by the Philippine National Police


    (PNP). In light of this ongoing case, a Memorandum was issued to the
    accused stating that the he is “reinstated to Panabo City” until the
    resolution of this case. Attached hereto is a copy of a Memorandum
    and marked as Annex “A”;

    2. The Memorandum was issued before the accused has submitted a


    copy of his bail bond amounting to SIX HUNDRED THOUSAND
    PESOS (P600,000.00). Attached hereto is a copy of the above-
    mentioned bail bond marked as Annex “B”’;

    3. In view of the above mentioned circumstances, A Watch List Order


    (WLO) against the accused has been issued by the Department of
    Justice (DOJ) upon application of the plaintiff attached and marked
    hereto as Annex “C”;

    4. Preventing the accused from leaving the country is proper considering


    that the crime charged against him is a serious offense;
    5. All precautions should be observed to ensure proper dispensation of
    justice.

    WHEREFORE, premises considered, it is respectfully prayed that a Hold


    Departure Order be immediately issues against the accused.

    Davao City, Philippines, March 14, 2020.

    ATTY. ERICK JAY N. INOK


    Counsel for the Plaintiff
    Notary Public / Roll of Attorneys No. 420696
    Notarial Commission Serial No. 2019-420-2020
    Commission Expires on December 31, 2020
    IBP No. 030524; 01/10/2020; Davao City
    PTR No. 1760152C; 01/04/2020; Davao City
    MCLE Compliance No. VI–0012697 – 09/19/2019
    Tel Nos. (082) 225-2066; (082) 241-2945
    Email Address: [email protected]
    Legal Office, Commission on Audit R.O XI, Davao City

    CONFORME:

    ATTY. RODRIGO DUTERTE


    Assistant City Prosecutor

    2
    NOTICE OF HEARING
    Atty. Salvador Pandesal
    The Brach Clerk of Court
    RTC Davao City, Branch 15

    Atty. Rudy Deterty


    For Accused Leo B. Escalante
    13 Digong St, Maa, Davao City

    Please take notice that the undersigned counsel will submit the
    foregoing Motion for the consideration and approval of the Court on March
    25, 2020 at 8:30 AM, with or without appearance of counsel.

    Atty. Erick Jay N. Inok

    Copy furnished:

    Atty. Rudy Deterty Registry


    Receipt._____________________
    13 Digong St, Maa, Davao City Date._______________________________

    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.

    Atty. Erick Jay N. Inok

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