REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
QUEZON CITY
BRANCH 1

PEOPLE OF THE PHILIPPINES

CRIM. CASE NO. 08-203040

-versus-

JOHN DOE
Accused.

x----------------------------------------------------x

MOTION FOR LEAVE TO TRAVEL ABROAD

COMES NOW the undersigned counsel for the accused in the

above-entitled case, respectfully moves this Honorable Court for
permission to travel abroad for business purposes and in support
thereof states:

1. That in an Order dated February 3, 2009 this Honorable Court

granted the private complainant’s “Motion for Issuance of Hold
Departure Order” against the accused;

2. That on November 5, 2009, the accused and the private

complainant entered into a Compromise Agreement, which was
approved by the Honorable Court on November 19, 2009;

3. That the accused has been diagnosed with Stage 3B colon

cancer;

4. That the accused to seek medical treatment in New York, U.S.A.;

5. That in view of the above urgent health concerns, the accused

is necessitated to travel abroad for a period of FIFTEEN (15) DAYS
onlyfromMarch 1-15, 2010;

6. That the accused’s medical certificate, flight schedules and

hotel accommodations are detailed in the itinerary prepared by the
travel agency, hereto attached as Annexes “1”, “2”, “3”, and “4”
respectively;

7. That the accused has been fully compliant with his obligations
under the said Compromise Agreement, and he is bent on complying
faithfully with all the conditions specified therein;
 8. That the accused is not a flight risk. The above requested travel
is necessary for his immediate medical treatment, and he will return to
the country as scheduled on March 15, 2010.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed on
this Honorable Court to grant this motion to allow the accused to travel
abroad solely for business purposes.

Other just and equitable reliefs are likewise prayed for.

RESPECTFULLY SUBMITTED.

Quezon City, February 10, 2010.

MEEZ CONGENIALY TY
Counsel for the Accused
PTR No.112345; Pasig City; 3 January 2010
IBP No. 23456; Pasig City; 5 January 2010
Attorney Roll No. 34567
MCLE Compliance III No. 0001111

123 Ditona Street

Pasig City
Telefax: (02) 666-6660
e-mail: congee@yey.com

NOTICE OF HEARING

THE CLERK OF COURT

Regional Trial Court
Branch 1, Quezon City

Assistant City ProsecutorAL CAPON

Office of the City Prosecutor
Quezon City Hall

Atty. Gringo Poe

Counsel for the Private Complainant
Rm 55, The Round Table
Quezon City
G R E E T I N G S:

Please take notice that the undersigned shall submit the foregoing
motion for the kind consideration and approval of this Honorable Court
on February 19, 2010 at 8:30 in the morning as counsel shall be heard.

MEEZ CONGENIALY TY

Copy Furnished:

Assistant City ProsecutorAL CAPON

Office of the City Prosecutor
Quezon City Hall

Atty. Gringo Poe

Counsel for the Private Complainant
Rm 55, The Round Table
Quezon City

Explanation

The undersigned counsel informs the Honorable Court that copy

of the foregoing motion was served upon theabove-named counsel by
registered mail due to distance and time constraints, and unavailability
of messenger to effect personal service.

MEEZ CONGENIALY TY