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Republic of the Philippines

Department of Justice
OFFICE OF THE PROSECUTOR
Hall of Justice, _______________
___________________

AAA, For:
Plaintiff,
RAPE (4 Counts)
In relation to RA 7610
-versus-
BBB,
Accused.

MOTION TO REOPEN THE INVESTIGATION AND TO ADMIT


THE ATTACHED SAGOT SA REPLY

COMES NOW, the Accused thru the undersigned counsel unto


this Honorable Office most respectfully alleges that:

During the preliminary investigation of the instant case, the


accused was assisted by the Public Attorneys Office and the
services of the undersigned was only secured during the latter
stage of the preliminary investigation;

On the clarificatory hearing scheduled on _______________, the


accused presented documents to the undersigned which are
vital to his defense but was not utilized in his Sinumpaang
Kontra-Salaysay. However, on the same date, the instant case
was submitted for resolution;

WHREFORE, in the interest of substantial justice, the accused


thru the undersigned counsel is praying that the preliminary
investigation be reopened and the attached SAGOT SA REPLY
be admitted and considered in evidence.

Date__________
_____________________