Republic of the Philippines

REGIONAL TRIAL COURT OF BOHOL

27TH Judicial Region

PEOPLE OF THE PHILIPPINES

Plaintif

-versus- Criminal Case No.

For: VIOLATION OF SEC. 5
and SEC. 11 of RA 9165

LYN NOG
Accused
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URGENT MOTION

COMES NOW, the accused, through counsel, unto this Honorable

Court respectfully alleges:

1. That the accused is presently detained at the Rehabilitation

Center;

2. That the father of the accused, Sun Nog, died on December 14,
2017. Attached hereto is the Death Certificate of the accused’s
father marked as “Annex A”;

3. That accused wants to attend the Requiem mass of his father’s

remains before it be laid to rest on December 22, 2017 at the Shine
Shrine Parish at 1:00 PM in the afternoon.

WHEREFORE, premises considered, it is respectfully prayed before

this Honorable Court that the accused be allowed to attend the Requiem
mass of his father’s remains before it be laid to rest on December 22, 2017
at the Shine Shrine Parish at 1:00 PM in the afternoon.

Counsel for Accused

Copy furnished:
THE HONORABLE PROSECUTOR

NOTICE OF HEARING

The Branch Clerk of Court

GREETINGS:

Kindly submit the foregoing Motion to the Honorable Court immediately upon
receipt, considering this an exception to the 3-day notice rule due to its urgency.

Thank you.

Counsel for Accused

The Honorable City Prosecutor

Madam/Sir:

Please take notice of the foregoing motion which undersigned counsels

will submit to the Honorable Court for its immediate consideration.

Thank you.

Counsel for Accused