Republic of the Philippines

Department of Transportation and Communication

LAND TRANSPORTATION FRANCHISING & REGULATORY BOARD
Regional Office No. VI, Iloilo City

______________________ Case No. ________

Respondent.
x----------------------------------x

COMPLIANCE
WITH MOTION TO LIFT ORDER OF PREVENTIVE
SUSPENSION

COMES NOW, Respondent _________________ through the

undersigned counsel and unto this Honorable Board, in compliance
with its order dated ______________, copy of which was received
by Respondent on ________________, most respectfully avers
that:

1. __________________________________________________
__________________________________________________
__________________________________________________
__________________;

2. In its Order dated _______________, which was received by

the Respondent on _______________, the Board required the
Respondent to submit within seventy-two (72) hours a Show
Cause in writing, stating among others, the reasons why the
Certificate of Public Convenience as issued to the subject case
should not be suspended, cancelled and/or revoked for
violations of the terms and condition of its franchise;

3. The said Order further directed Respondent to comply with

and submit within the 30-day preventive suspension the
following matters or documents:

a. The roadworthiness of the authorized PUB service of

respondent-operator bringing them to the Motor Vehicle
Inspection Service (MVIS) together with the authorized
representative of the Board
 b. Road Safety Seminar to be conducted or scheduled by
the Board and/or its authorized seminar provider

c. Compulsory Drug Testing of all respondent operators

drivers and conductors to be conducted by an
authorized/accredited agency of the Department of
Health and the Land Transportation Office

d. Certificates of Registration and latest Official Receipts of

all the units including the names of the respective
drivers and conductors

e. Video clippings of roadworthiness inspection, Road

Safety Seminar and Drug Testing

4. ___________________________________________________
___________________________________________________
___________________________________________________
__________________;

5. ___________________________________________________
___________________________________________________
___________________________________________________
__________________;

6. ___________________________________________________
___________________________________________________
___________________________________________________
__________________;

7. In correlation, Respondent humbly seeks the indulgence of this

Honorable Board to RECONSIDER its Order and to LIFT the
thirty (30) days preventive suspension and subsequently render
a decision, after due hearing and compliance, allowing the
buses covered by the subject franchise to resume its operation
considering that these buses are roadworthy and passed the
standards set forth by law.
 PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Board to reconsider and lift the imposed
preventive suspension and subsequently render a decision, after
due hearing, allowing the units covered by the franchise to resume
its operation.

Respondent likewise prays for other just and equitable relief

and remedies.

Most respectfully submitted. ______________________,

Philippines.

_________________________________
Counsel for the Respondent

By:
 VERIFICATION

I, ________________________, of legal age, Filipino,

married and a resident of__________________, after having been
duly sworn to in accordance with the law, hereby deposes and
states:

1. That I am the _________________________, the respondent

in the above-captioned case.

2. That I am duly authorized pursuant to a Secretary’s Certificate

issued by the company to represent in this case. Copy of the
said document is herein attached and marked as Annex “L”.

3. That I caused the preparation of the foregoing

(document/instrument title);

4. That I have read and understood the contents thereof;

5. That the allegations contained therein are true and correct out
of personal knowledge and based on authentic records.

IN WITNESS WHEREOF, I have hereunto set my hand this

_______________________ at _________________________,
Philippines.

_________________________
Affiant

SUBSCRIBED AND SWORN TO before me this

__________________ at _______________________, personally
appeared affiant exhibiting to me is competent evidence of
identification as indicated below his name.

Doc. No. _______;

Book No. _______;
Page No. _______;
Series of 2019.