Castro Vs AGNOTE - Cpo

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Republic of the Philippines

DEPARTMENT OF JUSTICE
CITY PROSECUTION OFFICE
Bonot, Legazpi City

LEONORA M. CASTRO,
Complainant,

NPS DOCKET NO. V-02-INV-09J-


00340
- versus - FOR: Acts of
Lasciviousness

GEROME AGNOTE y OLIVAR,


(ABIGAIL JUNE AGNOTE y OLIVAR),
Respondent.
x------------------------------------------------------x

APPEARANCE WITH
MOTION TO ADMIT COUNTER-AFFIDAVIT

Undersigned counsel, to this Honorable Office, respectfully sets forth


that:

1. He is formally entering his appearance as counsel for


respondent ABIGAIL JUNE AGNOTE y OLIVAR in the above-entitled case;

2. Consequently, he requests that all notices and other processes


in connection with the above-entitled case be furnished him.

By way of-

MOTION TO ADMIT

3. In compliance with the Subpoena dated 16 November 2009, he


hereby submits the Counter-Affidavit of respondent ABIGAIL JUNE O.
AGNOTE which is attached and marked as ANNEX “A”;

4. He likewise submits the Joint-Affidavit of respondent’s


witnesses REY MANDO y MAGDAONG and AARON JOSEPH ARAOJO y
AGUILAR which is attached and marked as ANNEX “2”.

WHEREFORE, premises considered, it is respectfully prayed of this


Honorable Office that the appearance of the undersigned counsel for
respondent ABIGAIL JUNE O. AGNOTE be noted and respondent’s
Counter-Affidavit and the Joint-Affidavit of his witnesses be admitted.
Legazpi City, 30 November 2009.

BARANDA BUSALLA & MAGISTRADO


LAW OFFICE
3/F Consumers Appliance Traders Bldg.
Peñaranda Street, Legazpi City 4500
Telefax: (052) 480-5645
Counsel for Respondent

By:

MARIANO B. BARANDA, JR.


PTR No. 1964463 dtd. 01-05-09
IBP No. 681533 dtd. 01-05-09
ROLL No. 26948 dtd. 4-29-77
MCLE EXEMPTION NO. II-002299 dtd. 12-10-
08

COPY FURNISHED BY REGISTERED MAIL:

LEONORA M. CASTRO
Complainant
No. 14-6 Tandang Sora St.
Pinaric, Legazpi City
-per Registry Receipt No. _____,
attached to the original hereof.

PROOF OF SERVICE WITH EXPLANATION

I, LUISA FE P. LOYOLA, under oath state: that I am one of the legal staff
in Baranda Busalla & Magistrado Law Office, that on _____ December 2009,
due to distance and lack of office personnel to effect personal service, I
served by registered mail with return card a copy of the foregoing
Appearance with Motion to Admit to LEONORA M. CASTRO at Pinaric, Legazpi
City.

LUISA FE P. LOYOLA
Affiant

SUBSCRIBED AND SWORN to before me this _____________________ at


Legazpi City, Philippines.

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