Republic of the Philippines

Sixth Judicial Region

REGIONAL TRIAL COURT
Branch 32
Manila

People of the Philippines,

Plaintiffs, Crim. Case No. 15-021391

For: Violation of Section 7,

- versus -
Article II of RA
9165 (Visiting a Drug
Claudio Claudio, et. al., Den)
Accused.
x---------------------------x

MOTION TO PLEA BARGAIN

The accused, CLAUDIO CLAUDIO, JAMES CLIFFORD, and

AMADEO AMADEO, through counsel, most respectfully state that:

1. Department Circular No. 27 of the Department of Justice dated June

26, 2018 provides that those charged under Section 7, Article II of RA
9165, as amended, can enter a plea of guilty to an offense of either
Section 12 (Possession of equipment, apparatus, and other drug
paraphernalia for dangerous drugs) or Section 15 (Use of dangerous
drugs).

2. As required under the same Department Circular, all offers for plea
bargaining must be initiated in writing by way of a formal motion
filed by the accused in court. Upon receipt of a proposal for plea
bargaining from the accused, the public prosecutor shall request the
court to order that a drug dependency assessment be administered,
which report is a condition sine qua non for the prosecution to give its
consent to the plea bargain.

3. From the above-premises, accused Claudio Claudio, James Clifford

and Amadeo Amadeo propose to withdraw their plea of not guilty to
Section 7, Article II of RA 9165, as amended, and offer to enter a plea
to the offense of Possession of equipment, drug apparatus, and other
paraphernalia, as defined and punished under Section 12, punishable
by imprisonment of 6 months & 1 day to 4 years.
 Attached to this motion are the respective Plea Bargaining Proposals
of Claudio Claudio, James Clifford, and Amadeo Amadeo as Annex
“A,” “B,” and “C,” respectively.

4. That their plea bargaining proposals are therefore submitted in order

that the conduct of the drug dependency assessment beordered.

PRAYER

WHEREFORE, above-premises considered, it prayed that the plea

bargaining proposals of the accused Claudio, Clifford, and Amadeo be
submitted and that the conduct of the drug dependency assessments be
ordered.

Other reliefs, just and equitable, are likewise prayed for.

Respectfully submitted. Manila City, October 17, 2018.

ATTY. JOHN JOHN JOHN

Counsel for the Accused
2/F John John Building, Doroteo Street, Manila
Roll of Attorneys No. 80888
PTR No. 626116 / Manila / June 19, 2018
IBP No. 042958 / Manila / May 28, 2018
MCLE Compliance No. Admitted to the Bar on June 8, 2018

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Branch 32
RTC – Manila

PROSECUTOR JOJIE JOJIE

Prosecutors Office
2nd floor, Manila Hall of Justice

Greetings!

Please take notice that the undersigned counsel submit the foregoing motion
for the consideration and approval of this Honorable Court on November 13,
2018 at 2:30 p.m.

ATTY. JOHN JOHN JOHN

Copy furnished:

Assistant Prosecutor Jojie Jojie

Prosecutors Office
2nd floor, Manila Hall of Justice

Received by: ________________________________

Date: _________________