Comment and Motions

Resetting todays arraignment and pre-trial by

the Court Social Worker.
Pp v Gina Tan y Reyes

July 26, 2018

Comment or Opposition (counsel for the
accused)

Re : Reckless Imprudence resulting in Serious

Physical Injuries.

X no crime.

X full blown trial.

/ dismissed right away.

/ victim was the victim of a motor accident

years ago.

Comment

Motion for Judicial Determination of Probable

Cause with Motion to Dismiss

(City Prosecutor)

Evidence by the complainant during the

preliminary investigation - unbelievable or
utterly incredible.

MOTION FOR REINVESTIGATION WITH ENTRY

OF APPEARANCE
X be dismissed because it needs submission and
appreciation of evidence. And only through full
blown trial.
> page 188

> all copies of orders, notices etc re the above

: must proceed to trial on merits. case be snet to the undersigned whose office
address I written below his name written below

Reason : this case is filed by the Prosecutors

? Constancia? Office without giving the accused a chance to
file a motion for reconsideration or petition for > the complaint lack probable cause according
review to the National Prosecutions Office or to to the defendant. It should be dismissed.
the Secretary of Justice.

> cannot travel more than the speed mentioned

> Motion for Reinvestigation in the case because of the deplorable condition
of the road, rugged, with pootholes and gravel
> Counsel of the accused
paved.

Manifestation and Motion

> the complainant only slipped and fell.

> Accused filed a Petition for Review to the Sec

> witnessed by several bystanders..she was only
of DOJ. (wait for the SEC of DOJ for the
scraped by long and pointy stones the reason
Petition.)
she suggested mefenamic.

MOTION FOR JUDICIAL DETERMINATION OF

> the medical certificate reveals that the victim
PROBABLE CAUSE WITH MOTION TO DISMISS
is an inborn pilay.

> accused has not been arraigned on the

charge.

> consistent stand of the accused that she never

committed the crime. > accused mentioned SEc 412 of the Road
Government Code of 1991. RA7160
: absence of probable cause and for the
consequent dismissal

: investigating prosecutor nonetheless

indicted her of the crime charged.
CRIM CASE no. Q-17-07827

Legal basis for the motion:

Reset Arraignment/Pre-trial

Rule 112, Section 5 (a) RR of criminal procedure.

Stated injury :

Fracture Closed complete displaced transverse

tibia-fibula, left

Counter-Affidavit with Motion to Dismiss