FORM NO.

7: MOTION FOR ISSUANCE OF A HOLD DEPARTURE ORDER

Republic of the Philippines

Fourth Judicial Region
REGIONAL TRIAL COURT
Branch 21, Imus City, Cavite

REPUBLIC OF THE PHILIPPINES,

Complainant,

-versus- CRIMINAL CASE NO. 9935-11

FOR: Qualified Theft
JASPER SOL CRUZ,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x

MOTION FOR ISSUANCE

OF A HOLD DEPARTURE ORDER

Private Complainant, by counsel, under the direct control and supervision of the Honorable
Public Prosecutor respectfully alleges that:

This is a criminal complaint for Qualified Theft under the Revised Penal Code against the accused.

Private complainant has reliable information that said accused is intending to go abroad to evade criminal
prosecution.

Consequently, to insure that accused do not leave the country to evade criminal prosecution and to
guarantee that he is properly brought before the bar of justice to face his charge, it becomes imperative
that he be placed in the “hold departure order” list of the Bureau;

For the guidance and information of the Court, we furnish the complete data, regarding accused JASPER
SOL CRUZ to wit;

Complete Name: JASPER SOL CRUZ

Sex : male
Civil Status : Separated
Complete Address : No. 866 W. Cornetto Street,
Malibay, Pasay City
Date of Birth : May 18, 1958
Birthplace : Tanauan, Batangas
Age : 54 years old

Photocopy of the photograph of the JASPER SOL CRUZ is hereto attached as Annex “A” for
easy reference.

WHEREFORE, premises considered, it is respectfully prayed that this Honorable Court issue an
order directing the Commissioner of the Bureau of Immigration to place accused JASPER SOL CRUZ in
their “Hold Departure Order” list.
 Other relief and remedies just and equitable under the premises are prayed for.

City of Manila, for Imus City, 25 July 2011.

PARIL LAW OFFICE

Counsel for Private Complainant
1080 Negros Street, Balic- Balic
Sampaloc, Manila

by:

JEFFREY PARIL
IBP#941296, Sampaloc Chapter, 12-27-2010
PTR#176413, Sampaloc, Manila, 1-2-2012
Attorney’s Roll No. 48000
MCLE Compliance No. II- 0009569
MCLE Compliance No. III- 0000923
MCLE Compliance No. IV- 0007733

With my conformity and

Under my control and supervision:

PROSECUTOR JACK MIOF

Asst. City Prosecutor

Notice

Office of the City Prosecutor

Imus City, Cavite

CLERK OF COURT
Regional Trial Court
Branch 21, Imus City

ATTY. RAPHAEL CORONADO

2nd Floor, RCVJ Building,
Don P. Campa Avenue, Barrio Uno,
2662 Dasmarinas City, Cavite

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,
Aguinaldo Highway, Perpetual Village,
Palico III, Imus City, Cavite
Greetings:

Please be notified the undersigned has requested the Branch Clerk of Court to include the foregoing
Motion in the Court Calendar on August 23, 2011 at 8:30 a.m. that counsel and matter may be heard.

JEFFREY PARIL

Copy furnished:
Office of the City Prosecutor
Imus City, Cavite

ATTY. RAPHAEL CORONADO

2nd Floor, RCVJ Building,
Don P. Campa Avenue, Barrio Uno,
2662 Dasmarinas City, Cavite

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,
Aguinaldo Highway, Perpetual Village,
Palico III, Imus City, Cavite
Explanation

Copy of the Motion was furnished to the respondent by private courier due to the distance of the
undersigned from the said parties, making personal service thereof not practicable.

JEFFREY PARIL