Republic of the Philippines

MUNICIPAL TRIAL COURT OF BALIUAG

PROVINCE OF BULACAN

PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case Nos. 000000000000

For: RECKLESS IMPRUDENCE RESULTING
TO DAMAGE TO PROPERTY; RECKLESS
IMPRUDENCE RESULTING TO SLIGHT
PHYSICAL INJURIES and VIOLATION
OF SECTION 48 OF R.A. 4136
ZZZZZZZZZZZZ,
Accused.
x- - - - - - - - - - - - - - - - - - - -x.

URGENT EX-PARTE MOTION TO RESET

Accused, ZZZZZZZZ, to this Honorable Court in the above-entitled case

most respectfully moves and prays for the cancellation of the arraignment and

preliminary conference scheduled on 26 February 2013 at 1:30 o’clock in the

afternoon due to Motion to Withdraw filed by the counsel de parte filed on

February 26, 2013.

This motion is not intended to unduly delay the disposition of the above-

entitled case but only for the reason above-mentioned, to give time for the

accused to procure the services of an effective counsel to defend the herein

accused.

Accused humbly prays that the scheduled special hearing be reset to

another date most preferably on March 26, 2013 at 1:30 o’clock in the

afternoon.
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

begging the kind indulgence and understanding of the Hon. Court as well as

the other party that the hearing on 26 February 2013 at 1:30 o’clock in the

afternoon be cancelled and the same be reset to another date most preferably

on March 26, 2013 at 1:30 o’clock in the afternoon.

MOST RESPECTFULLY SUBMITTED.

Baliuag, Bulacan, 26 Febrruary 2013.

ADMINISTERING OFFICER
THE CLERK OF COURT
MTC, BALIUAG
BULACAN

G r e e t i n g s:

Please submit the foregoing Motion for the favorable consideration and
approval of the Hon. Court immediately upon receipt hereof.

ZZZZZZZZZZ

Copy furnished:

ATTY. YYYYYYYY
Public Prosecutor
Baliuag, Bulacan

XXXXXXXX
Private Complainant
Brgy. Tenejero
Candaba, Pampanga