Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region
Branch xxx
Zamboanga City

PEOPLE OF THE PHILIPPINES Crim. Cases No. xxx

Plaintiff,
-versus- -for-
XXX VIOLATION OF R.A. NO. 9165
Accused.
x--------------------------x

VERY URGENT EX-PARETE MOTION TO ALLOW ACCUSED TO ATTEND

THE FUNERAL RITES AND INTERMENT OF HIS LATE FATHER

COMES NOW, herein Accused xxx, by and through undersigned counsel, unto
this Honorable Court, most respectfully submit this Motion to Allow Accused to Attend
the Wake of his late father at their house at xxx, Zamboanga City, and hereby depose and
state that:

1. That the accused is presently being detained at the Zamboanga City Jail.

2. On August 4, 2018, the father of herein Accused whose name is xxx had passed
away and his body lies in state at their residence in xxx, Zamboanga City;

3. The funeral rites of his father will be held at xxx Parish followed by the interment
at the xxx Cemetery on August 11, 2018 at around 8:00 o’clock in the morning;

4. It is for humanitarian reasons and basic human decency that the accused wishes to
pay his last respects before his father is buried.

WHEREFORE, premises considered, herein Accused, through counsel, most

respectfully pray unto this Honorable Court that he be momentarily released from his
detention in order to allow him to attend the funeral rites and the interment of late father,
and to direct the city jail warden to provide the necessary escort for the said purpose, and
for whatever is just and legal under the said premises.

Zamboanga City, Philippines, August 10, 2018

ATTY. xxx
xxx

The Branch Clerk of Court

RTC, Branch xxx
Zamboanga City

The City Prosecutor

Hall of Justice
Sta. Barbara
Zamboanga City
Greetings:

Please submit the foregoing motion for consideration and approval of the
Honorable Court immediately upon receipt hereof, and without further oral argument.

xxx

The City Prosecutor

Hall of Justice
Sta. Barbara
Zamboanga City

G r e e t i n g s:

Please take notice that the foregoing motion is being submitted for the
consideration and approval of the Honorable Court immediately upon receipt hereof, and
without further oral argument.

xxx