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    Doj Motion For Leave

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    Anonymous 5tvQLErp
    This document is a motion filed by the complainant's counsel requesting leave to rectify or correct an annex attached to their previous opposition. Specifically, the complainant alleges that the counter-affidavit attached in the respondent's motion is mistaken and not a party to the case. The complainant is asking the prosecutor's office to allow them to correct the annex. They pray that their motion be granted to rectify the annex to their opposition to the respondent's motion to admit counter-affidavit.

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    Doj Motion For Leave

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    Anonymous 5tvQLErp
    46 views3 pages
    This document is a motion filed by the complainant's counsel requesting leave to rectify or correct an annex attached to their previous opposition. Specifically, the complainant alleges that the counter-affidavit attached in the respondent's motion is mistaken and not a party to the case. The complainant is asking the prosecutor's office to allow them to correct the annex. They pray that their motion be granted to rectify the annex to their opposition to the respondent's motion to admit counter-affidavit.

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    Doj Motion for Leave

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    This document is a motion filed by the complainant's counsel requesting leave to rectify or correct an annex attached to their previous opposition. Specifically, the complainant alleges that the counter-affidavit attached in the respondent's motion is mistaken and not a party to the case. The complainant is asking the prosecutor's office to allow them to correct the annex. They pray that their motion be granted to rectify the annex to their opposition to the respondent's motion to admit counter-affidavit.

    Copyright:

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

    Doj Motion For Leave

    Uploaded by

    Anonymous 5tvQLErp
    This document is a motion filed by the complainant's counsel requesting leave to rectify or correct an annex attached to their previous opposition. Specifically, the complainant alleges that the counter-affidavit attached in the respondent's motion is mistaken and not a party to the case. The complainant is asking the prosecutor's office to allow them to correct the annex. They pray that their motion be granted to rectify the annex to their opposition to the respondent's motion to admit counter-affidavit.

    Copyright:

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

    DEPARTMENT OF JUSTICE

    OFFICE OF THE CITY PROSECUTOR


    PARAAQUE CITY

    FRESHEVER INCORPORATED
    Represented by: CHRISTER BRIAN
    DEL ROSARIO
    Complainant.
    -versus- I.S No.XV-12-
    INV-15-G-01619
    For: Estafa and
    Violation of B.P.22
    FRANCIS JUAN
    Respondent.
    X- - - - - - - - - - - -X

    MOTION
    (For Leave to Rectify/Correct
    The Annex to Our Opposition)

    COMES NOW, the Complainant in the above-


    entitled case by and through Undersigned Counsel
    and unto this Honorable Prosecutor Office, most
    respectfully avers:

    1.That on September 14, 2015 the Complainant


    through counsel submit Opposition to the
    Motion of the Respondent to Admit Counter-
    Affidavit.
    2.That in the Opposition, the complainant
    alleged that the said Counter- Affidavit
    attached in the respondent Motion is a
    MISTAKE, NOT A PARTY IN THIS CASE, that
    herein respondent still failed to submits its
    Counter-Affidavit.
    3.That the complainant humbly asking the
    Honorable Office to rectify/correct the
    annex attached in the opposition submitted.
    4.That the copy of the said respondent Motion
    to Admit Respondent Counter-Affidavit be
    attached as Annex A
    5.That the Complainant prays that leave be
    Granted unto the Complainant Opposition to
    the Motion to Admit Respondent Counter-
    Affidavit.

    P R A Y E R
    WHEREFORE, it is most respectfully prayed
    of this Honorable Prosecutors Office that the
    Motion For leave to rectify/correct the annex of
    the Opposition to the above-entitled case be
    admitted.

    All other reliefs, just and equitable


    under the premises, are likewise prayed for.

    City of Manila for Paranaque September 30,


    2015.

    ATTY. LEOPOLDO P. DELA ROSA


    Counsel for the Complainant
    Suite 307 CCI Building
    1091 Concepcion Street
    Ermita, Manila
    IBP No. 974764/Manila/ 09-11-14
    PTR No. 3827412/Manila/12-29-14
    Roll No. 28195
    MCLE Compliance No. IV-0020667
    June 13, 2013

    NOTICE
    HON. ACP AMERHASSAN C. PAUDAC
    City Prosecutor
    Office of the City Prosecutor
    Paranaque City

    FRANCIS JUAN
    C/O PIER 1 BAR & GRILL HOLDINGS CORP.
    Cabrera Road, Kaytikling,
    Brgy. Dolores, Taytay, Rizal

    Greetings

    Please take Notice that Undersigned will submit the forgoing


    Motion for the kind consideration and approval of the Honorable
    Investigating Prosecutor, immediately upon receipt hereof.

    ATTY. LEOPOLDO P. DELA ROSA

    EXPLANATION
    This is to certify as an Officer of the Court that a copy of this
    Motion was served, not by personal service but by registered mail as
    herein-below indicated by reason of time, distance, lack of manpower
    and urgency.

    ATTY. LEOPOLDO P. DELA ROSA

    Copy furnished:

    FRANCIS JUAN
    C/O PIER 1 BAR & GRILL HOLDINGS CORP.
    Cabrera Road, Kaytikling,
    Brgy. Dolores, Taytay, Rizal

    Cc//macel

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