Professional Documents
Culture Documents
LEX LUTHOR,
Accused.
x-------------------------------------------x
1. Accused-applicant is of legal age and currently gainfully employed at San Miguel Corporation
located at Ortigas Avenue, Pasig City. On December 7, 2011 she pleaded “guilty” to the offense
charged herein; consequently, this Honorable Court in its Order dated 10 December 2011
sentenced accused-applicant to an indeterminate penalty ranging from three (3) years to five (5)
years of prision correccional.
2. Accused-applicant humbly submits that she possesses all the qualifications and none of the
disqualifications enumerated under section 2 of Presidential Decree No. 968, specifically:
2.1. She has not been convicted of any crime against national security or public order;
2.2. She has not been previously convicted by final judgment of an offense punishable by
imprisonment of not less than one (1) month and one (1) day and/or a fine of not less than Two
Hundred Pesos (P200.00);
2.3. She has not previously applied for nor had been previously placed under probation
under Presidential Decree No. 968.
2.4. She has not started to serve her sentence and, to date, has not filed any Notice of
Appeal from the Order of conviction.
3 Finally, granting this application will not in any way depreciate the seriousness of the offense
charged nor cause any undue risk that during the period of probation, accused-applicant will
commit another crime. Moreover, accused-applicant does not need any correctional treatment
requiring commitment to an institution.
1
WHEREFORE, accused-applicant respectfully prays that her application for probation be
GRANTED and that she be placed under probation under such terms and conditions necessary to
attain and ensure the objectives of the law and which, under the circumstances, are fair, just and
reasonable in the sound discretion of this Honorable Court.
Please submit the foregoing Motion to the Court for its consideration and approval immediately
upon receipt hereof and kindly include the same in the court’s calendar for hearing on December
25, 2011 at 8:30 in the morning.
ATTICUS FINCH
1 MockingBird Street
Please take notice that counsel has requested to be heard on December 25, 2011 at 8:30 in the
morning.