Motion for Release of Vehicle

 

REPUBLIC OF THE PHILIPPINES

Department of Justice

OFFICE OF THE PROVINCIAL PROSECUTOR

(Office Address)

 

 

(NAME OF COMPLAINANT),

                                    Complainant,

            -versus-                                                          NPS Docket No. _______________

                                                                                    For: Reckless Imprudence Resulting in

(NAME OF RESPONDENT),                            Homicide and Damage to Property

Respondent.

x-------------------------------------------/

 

 

MOTION FOR RELEASE OF VEHICLE

 

            COMES NOW, (NAME OF MOVANT), by himself, unto the Honorable Provincial Prosecutor’s Office most respectfully states that:

 

1.     The movant with residential address at (Address of Movant), is the registered owner of a (Brand and Model of Vehicle) with plate number (Plate Number), particularly described as follows:

 

MAKE:                       ___________

                                    ENGINE NO.:           ___________

                                    CHASSIS NO.:          ___________

                                    COLOR:                     ___________

                                    MV FILE NO.:          ___________

                                    PLATE NO.:              ___________

 

2.    Attached herewith are copies of the Official Receipt and the Certificate of Registration as Annex “A” and “B”, respectively.

 

3.    That, the said motor vehicle, driven by (NAME OF DRIVER-RESPONDENT), was involved in a vehicular accident on (Date of Accident) at about (Time of Incident) in (Place of Accident) causing the death of (NAME OF VICTIM) and damage to the car driven by the victim.

 

4.    The said motor vehicle driven by (Name of Driver-Respondent) was impounded and currently under the custody of the (Police Station / Highway Patrol Group / LTO).

 

5.    The movant herein most respectfully requests for the immediate release of the impounded vehicle in view of the fact that the continued impounding of said vehicle would further cause its deterioration.

 

6.    The 2^ndparagraph of Article 45 of the Revised Penal Code exempts the property owned by a third person not involved in the incident from being confiscated and forfeited in favor of government.

 

7.     The said vehicle is not owned by respondent-driver but by herein movant who is not a party to this case.

 

8.    And as since the vehicle had already been processed by the police/traffic investigators at the scene of the incident, its further detention is no longer warranted.

 

9.  Undersigned movant undertakes to present the said motor vehicle, if released, whenever required by your Honorable Office or by any court of law.

 

 

PRAYER

 

            WHEREFORE, premises considered, it is respectfully prayed of the Honorable Provincial Prosecutor that the impounded motor vehicle owned by herein movant be released.

 

            Other reliefs, which are just and equitable, are also prayed for.

 

            (Date of Filing), (Place of Filing), Philippines.

 

 

                                                               (NAME OF MOVANT)

                                                                                                    Movant

 

 

Copy furnished:

 

(Rank and Name of Police/LTO Chief)

Chief of Police / Head of Office

(Office Address)

Motion to Dismiss (Settlement)

 

Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No. ___

________ City

 

(NAME OF HON. LABOR ARBITER)

 

 

NAME OF COMPLAINANT,                      NLRC CASE NO. _____________

Complainant,

                                                     

         -versus-                                  

                                                                                           

NAME OF RESPONDENT,

                           Respondent.

x-----------------------------------------/

 

 

MOTION TO DISMISS

 

         RESPONDENT, through undersigned counsel, most respectfully submits this Motion and states, THAT:

 

1.   The parties in the instant case have agreed to amicably and fully settle all the issues affecting the aforementioned case and complainant has executed Release Waiver and Quitclaim, duly attested by two witnesses. Copies of Quitclaim, Waiver and Release is hereto attached as Annex “A”;

 

2.   Pursuant to the above Quitclaim, Waiver and Release, respondent is hereby submitting the instant Motion to Dismiss the aforementioned case from this Honorable Office and dismiss any and all existing claims arising therefrom.

 

 

PRAYER

 

         WHEREFORE, premises considered, it is respectfully prayed of this Honorable Commission to DISMISS the instant case RAB _______________, and any and all claims arising therefrom with prejudice and to drop the said case from the business calendar of the case.

 

         Other reliefs, just and equitable under the premises, are likewise prayed for.

        

         (Date), (Place), Philippines.

 

 

 

LAWYER DETAILS

 

Copy furnished:

 

COMPLAINANT

Address of Complainant 

 

 

NOTICE

 

 

The Hon. Clerk of NLRC-RAB________

___________ City

 

            GREETINGS!

 

            Please be advised that the foregoing Motion is submitted for the due consideration and approval of this Honorable Office immediately upon receipt hereof sans any oral argument on the part of the undersigned.

 

 

 

                                                           LAWYER

Ex-Parte Motion to Investigate for Collusion of Parties

 

Republic of the Philippines

REGIONAL TRIAL COURT

_____ JUDICIAL REGION

Branch ______

_______ City

 

 

NAME OF PLAINTIFF,

                           Plaintiff,

                                                              Civil Case No. ___________

                  - versus –                              For: Declaration of Absolute Nullity

of Void Marriage Under Art. 36 of the Family Code

NAME OF DEFENDANT,                              

                           Defendant.

x---------------------------------------------/

 

 

EX-PARTE MOTION TO INVESTIGATE FOR COLLUSION OF PARTIES

 

 

         PLAINTIFF, by counsel, most respectfully avers:

 

Summons was served to defendant on January 18, 2017 per the January 21, 2017 Court Process Server’s Return.

 

Until date, or more than fifteen (15) days after, the defendant failed to serve or file an Answer.

 

We wish to invoke Section 8 par. 3 of the Rule on Declaration of Absolute Nullity of Void Marriages and Annulment of Voidable Marriages, and thereunder respectfully beg that an order be issued directing the public prosecutor to investigate whether collusion exists between the parties.

 

RESPECTFULLY FILED by registered mail due to considerable distance, February 28, 2017.

 

_________ City (for ________ City), Philippines.

 

 

NAME OF LEGAL COUNSEL

Lawyer Details

 

Notice of Hearing

 

Copy furnished –

 

[ ] by personal service:

 

HON. PROVINCIAL PROSECUTOR

Province of______

Address

 

[ ] by registered mail due to considerable distance:

 

HON. SOLICITOR GENERAL

Office of the Solicitor General

134 Amorsolo St., Legaspi Village                 Registry Receipt No. ____________

1229 Makati City                                             Date & Place: __________________

 

 

[ ] by registered mail due to considerable distance:

 

            NAME OF DEFENDANT

            Address                                                          Registry Receipt No. ____________

                                                                       Date & Place: __________________

 

 

Greetings:

 

            Please do take notice that the foregoing, due to its urgency, shall be heard and submitted unto the kind attention of the Honorable Court for resolution and approval on _______________ or as soon as this can be heard sans appearance of counsel.

 

 

NAME OF LEGAL COUNSEL

Request

 

HON. CLERK OF COURT

Hon. RTC, Branch ___

Hall of Justice

________ City, _________

 

Greetings:

 

            Please do cause the foregoing to be heard on the date and time above appointed or as soon as this can be heard by the Honorable Court sans appearance of counsel. Thank you.

 

 

                                                                                    NAME OF LEGAL COUNSEL