Republic of the Philippines

REGIONAL TRIAL COURT

BRANCH 1
PROVINCE OF LANAO DEL NORTE
Hall of Justice, Carbide Village, Tubod, Iligan City

SKYLER A. WHITE Criminal Case No. 34-001

Plaintiff

-versus-
FOR: QUALIFIED
TRESPASS TO
DWELLING UNDER
R.A. NO. 3815, AS
AMENDED (THE
REVISED PENAL
CODE)

HENRY R. SCHRADER
Defendant
X---------------X

Motion to Suspend Proceedings with Motion

to Suspend Issuance of Warrant of Arrest
I, SAUL GOODMAN, counsel for the defendant, HENRY
R. SCHRADER in the above-captioned case, hereby
respectfully submit this motion to suspend proceedings along
with a motion to suspend the issuance of a warrant of arrest.

GROUNDS FOR THE MOTIONS:

I. Pending Legal Proceedings
The instant criminal case is currently pending before this
Honorable Court, with the Defendant facing charges of
Qualified Trespassing under R.A. 3815. However, certain legal
proceedings, the Motion for Reconsideration, docketed as NPS
NO. 023215-CB521042, filed 27th day of March 2024, is still
pending to the Department of Justice for review. Furthermore,
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it is essential to ensure a fair and just adjudication of the case
by allowing all legal processes to proceed smoothly and
without undue haste or prejudice to any party involved.
II. Motion to Suspend Proceedings
The Rule 116, Section 11 (c) of the Criminal Procedure
states that “upon motion by the proper party, the arraignment
shall be suspended in the one of the following cases: (c) A
petition for review of the resolution of the prosecutor is
pending at either the Department of Justice, or the Office of
the President; provided, that the period of suspension shall
not exceed sixty (60) days counted from the filing of the
petition with the reviewing office.” Hence, we respectfully move
this Honorable Court to suspend the proceedings in the
above-captioned case until such time as the pending legal
matters are resolved in the Department of Justice.
Additionally, we respectfully move this Honorable Court to
suspend the issuance of any warrant of arrest against the
Defendant pending the resolution of the aforementioned
proceedings of the motion for reconsideration that is still
under review by the Department of Justice. Given the
pendency of the prosecutor's resolution of the motion for
reconsideration at the Department of Justice, the court may
suspend the issuance of the warrant of arrest until a final
decision is made on the review.

PRAYERS
IN VIEW OF THE FOREGOING, we respectfully request
that this Honorable Court suspend the proceedings in the
above-captioned case until such time as the pending legal
matters are resolved, in accordance with Rule 116, section 11
paragraph C of the Rules of Criminal Procedure. We further
request that this Honorable Court suspend the issuance of
any warrant of arrest against the Defendant pending the
resolution of the motion for reconsideration in dismissing the
case, pending at the Department of Justice, submitted 27th
day of March 2024. Given the importance of ensuring a fair
and just adjudication of the case, we request that these
motions be given expedited consideration by the Honorable
Court.

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 CONCLUSION
In the interest of justice and fairness, it is essential to
suspend the proceedings and the issuance of any warrant of
arrest, pending the resolution of the motion for
reconsideration in dismissing the complaint submitted by
Skyler A. White, at the Department of Justice.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 30th day of March 2024, in Iligan City.

HENRY R. SCHRADER
Defendant/Affiant

SUBSCRIBED AND SWORN TO before me this 30th day

of March 2024 in Iligan City.

SAUL GOODMAN
Defendant’s Counsel