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Motion To Release - Provincial Prosecutor's Office

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52 views3 pages

Motion To Release - Provincial Prosecutor's Office

Uploaded by

p7tmb55xpm
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTION
_______ CITY

MOTION TO RELEASE (BUS 1630)

Case No.
For: _____

CHIEN HSIN LEE C. LEE


Applicant.
x---------------------x

MOTION TO RELEASE VEHICLE

COMES NOW, Applicant authorized representative, CHIEN HSIN


LEE C. LEE, and unto the Office of the Provincial Prosecutor, ____ City,
respectfully avers that:

1. Applicant, CHIEN HSIN LEE C. LEE, of legal age, Filipino, single,


and a resident of 904 Ipilan Tayabas, Quezon;

2. He is the authorized representative of BICOL ISAROG TRANSPORT


SYSTEM INC., A copy of the Secretary Certificate issued by BICOL
ISAROG TRANSPORT SYSTEM INC., is hereby attached as Annex
“A”;

3. One of its fleet with Bus Number 1630 bearing Plate No. ___ was
driven by _____________ was involved in a vehicular accident last
June 17, 2024, that was entered in Police Blotter of PNP Atimonan,
Quezon, and docketed as ___________ in the records of this
Honorable Office;

4. As a consequence, the said vehicle was impounded by the police


officer;

5. Herein Applicant, as the authorized representative of the company


is not in any way involved in any crime or illegal of the driver, if
there was any, or whatsoever, in violation of law or ordinance;

6. The said Bus is being used every day in the ordinary course of
business of the company;

7. As result thereof, herein petitioner is suffering and further


incurring losses in the meantime that the case against its driver is
still pending; and

8. Applicant has already executed the corresponding affidavit of


undertaking to cooperate if necessary for the immediate resolution
or settlement of the abovementioned case. Copy of the affidavit of
undertaking is herein attached as Annex “B”.

PRAYER

WHEREFORE, it is respectfully prayed unto the Honorable Office


that this petition be considered and that the said vehicle (Bus 1630) be
released.

_________ City, Philippines, 27 June 2024.

CHIEN HSIN LEE C. LEE


Applicant

VERIFICATION

I, CHIEN HSIN LEE C. LEE, of legal age, Filipino, single, and a


resident of 904 Ipilan Tayabas, Quezon, after having been duly sworn by
law, hereby depose and say that;

1. I have caused the preparation of the foregoing motion;

2. I have read the contents of said motion and that all the allegations
contained thereon are true and correct to the best of my knowledge
and belief;

3. I have not commenced any other action or proceeding involving the


same issues in the Supreme Court (SC), the Court of Appeals (CA),
or any other tribunal or agency; and

4. If I should thereafter learn that a similar action or proceeding has


been filed or is pending before the tribunal or agency, I undertake
to report this fact within five (5) days therefrom to the court or
agency wherein the original pleading and this certification have
been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this


_______________ at ______________________________.

CHIEN HSIN LEE C. LEE


Applicant
SUBSCRIBED AND SWORN TO before me on this ______________ at
______________ City. I hereby certify that I have personally examined
aboved-named affiant who executed the foregoing Verification. Affiant
further exhibited to me his Philhealth ID Number 02-026573268-3. I am
convinced that the foregoing is his true and voluntary act and deed.

NOTARY PUBLIC

Doc. No. _____


Page No. _____
Book No. _____
Series of 2024

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