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1) The accused, through their counsel, has filed a motion for production and inspection of documents with the regional trial court.
2) The motion requests that the prosecution provide certified copies of the complainant's affidavits and photographs taken by arresting officers that are related to criminal case number 969-31.
3) The defense counsel argues these documents are needed to prevent evidence tampering and to adequately prepare counter-allegations for the case.
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Motion for the Production and Inspection of Documents
1) The accused, through their counsel, has filed a motion for production and inspection of documents with the regional trial court.
2) The motion requests that the prosecution provide certified copies of the complainant's affidavits and photographs taken by arresting officers that are related to criminal case number 969-31.
3) The defense counsel argues these documents are needed to prevent evidence tampering and to adequately prepare counter-allegations for the case.
1) The accused, through their counsel, has filed a motion for production and inspection of documents with the regional trial court.
2) The motion requests that the prosecution provide certified copies of the complainant's affidavits and photographs taken by arresting officers that are related to criminal case number 969-31.
3) The defense counsel argues these documents are needed to prevent evidence tampering and to adequately prepare counter-allegations for the case.
Brutus Bottom, Accused, x ---------------------------------------------- x
MOTION FOR THE PRODUCTION AND INSPECTION OF DOCUMENTS
Accused, through undersigned counsel, to this most Honorable Court, respectfully states that:
1.At the last hearing held last February 14, 2013, the undersigned private counsel repeated its request to the prosecution to provide the former with certified copies of the affidavits of the complainant as well as the photographs taken by the arresting officers of the Center Turn Police District; 2.That up to present time, no copies were furnished to the accused or his undersigned counsel; 3.That said copies are urgently needed in order to prevent unnecessary alteration and suppression of records on the part of the prosecution and; 4. To justifiably allow the defense to sufficiently prepare its counter-allegations against the said complainant. 5. This motion is made pursuant to Section 10 of Rule 116 of the 1997 Revised Rules of Criminal Procedure.
PRAYER
WHEREFORE, the foregoing premises thoroughly considered, in the interest of substantial justice, it is most respectfully prayed that an Order for the Production and Inspection of Documents be issued, requiring the Hon. Prosecutor Hap Chan; 1) to furnish the counsel for the accused all the records, affidavits and photographs related in the abovementioned case.
Other just and equitable reliefs are likewise humbly prayed for.
City of San Fernando, March 2, 2013.
(Sgd.) Atty. Rommelito Francisco E. Macarayo Counsel for the Accused 13-69 Barracks Building, Marikina IBP NO. 87123-7/19/12-AC PTR NO. 669913/21/12-AC Roll No. 99998 MCLE Exempt (Admitted to the bar: April 6, 2012)
NOTIFICATION AND COPY FURNISHED:
ANTONIO ANTONIO L. SANTOS City Prosecutor City of San Fernando Pampanga
The Branch Clerk of Court RTC Branch 16 City of San Fernando Pampanga
Greetings!
Please take notice that the foregoing Motion shall be submitted for the consideration and resolution of the Honorable Court on 5 March 2013 at 10:45 A.M., or as soon as counsel and matter may be heard.
Atty. Rommelito Francisco E. Macarayo
EXPLANATION
The foregoing Motion is being filed with this Honorable Court and served on the opposing counsel by registered mail in view of the impracticability of personal filing and service due to distance considering that the office of this Honorable Court is at the City of San Fernando, while undersigned counsel holds office in Marikina.
Atty. Rommelito Francisco E. Macarayo
COPY FURNISHED:
Atty. Antonio Antonio L. Santos City Prosecutor City of San Fernando Pampanga