Motion To Release Cash Bond and Evidence

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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


xxxxxxx
xxx

PEOPLE OF THE PHILIPINES,

-versus- Crim. Case No. xxxx

xxxxxxx
Accused.
X---------------------------------------------X

MOTION TO RELEASE CASH BOND


AND MOBILE PHONE (EVIDENCE)

MOVANT xxxxxxxxxxxx, assisted by the xxxxxxxxxxxxxxxxxxx,


through the undersigned counsel, and unto this Honorable Court, most
respectfully aver:

1. Cash bond in the amount of EIGHTEEN THOUSAND PESOS


(P18,000.00) was posted for the provisional liberty of the accused
xxxxxxxxxxxxxx under Official Receipt No. xxxxxxxxxxxxxxxx,
dated xxxxxxxxxxxxxxx. The original receipt is attached in the
court record as p. 28;

2. When the movant was arrested, his xxxxxxxxxxxxx Mobile Phone


was confiscated, and is currently in the custody of
xxxxxxxxxxxxxxxx, as evidenced by a CERTIFICATE OF
CUSTODY OF EVIDENCE attached in the court record as p. 24;

3. xxxxxxxxxxxxx, movant received the ORDER of the Honorable


Court, xxxxxxxxxxxxxx, GRANTING the Demurrer to Evidence
and DISMISSING the instant case against him.

WHEREFORE, premises considered, it is most respectfully prayed


unto this Honorable Court that an ORDER be issued allowing the release
of the cash bond of the accused, and Ordering xxxxxxxxxxxxx to return
the xxxxxxxxxxxxxxx to the MOVANT.

Other just and equitable reliefs are likewise prayed for.


Respectfully filed. City of Malolos, Bulacan. xxxxxxxxxxxx.

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

NOTICE

MS. xxxxxxxxxxxx
The Branch Clerk of Court
xxxxxxxxxxx
xxxxxxxxxxxxxx

Greetings.

Please submit the foregoing MOTION for the consideration and


approval of the Honorable Court immediately upon receipt hereof.

Thank you.

xxxxxxxxxxxxxxxxx

Copy Furnished:
xxxxxxxxxxxxxxxxxxx

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