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A.

Motions 1. Motion to dismiss (with request for and notice of hearing) Republic of the Philippines National Capital Judicial Region METROPOLITAN TRIAL COURT Branch 39, Quezon City PLUS: [5] Proof of Service 2.

Counsel for Defendant 2 The Firm Laguna Street, Quezon City

LAKI ASSET COMPANY, Plaintiff, 3333 - versus -

Motion for leave of court to file pleading (with explanation for service by registered mail) Republic of the Philippines SUPREME COURT Manila G.R.

Civil Case No. For: Sum of Money LAKI UTANG, Petitioner, No. ________ - versus MOTION TO DISMISS DAMI LUPA, Respondent. x ------------------------- x

DAMI UTANG CORPORATION, Defendant. x --------------------------------------- x

DEFENDANT, by counsel, respectfully moves to dismiss the Complaint on the ground that the Complaint fails to state a cause of action as [1] THE OBLIGATION SOUGHT TO BE ENFORCED BY PLAINTIFF IS NOT YET DUE AND DEMANDABLE, as shown by the following: [2] 1. Allegedly, plaintiff has failed to reach the quotas agreed upon under the Marketing Agreement dated 1 January 2006; defendant now seeks to collect the sum of TWO HUNDRED THOUSAND PESOS (P200,000.00), representing the balance of the proceeds due plaintiff under the said Marketing Agreement. 2. The contract is for one (1) year and defendant is given that same period to reach the quota specified therein; the period of one (1) year has not expired. Consequently, plaintiffs claim is premature as there is yet no breach of the Marketing Agreement until the period expires and the quota is not attained. For this reason, plaintiffs Complaint states no cause of action and must be dismissed. [3] WHEREFORE, defendant respectfully prays that the Complaint be DISMISSED for failure to state a cause of action. Other just and equitable reliefs are also prayed for. Quezon City; 13 April 2007. (Sgd.) MITCH MCDEERE Counsel for Defendant [Address] [4] REQUEST FOR & NOTICE OF HEARING THE BRANCH CLERK OF COURT Metropolitan Trial Court Branch 39, Quezon City Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the courts calendar for hearing on Friday, 27 April 2007 at 8:30 in the morning. ATTICUS FINCH 1 MockingBird Street Timog Avenue, Quezon City Please take notice that counsel has requested to be heard on Friday, 27 April 2007 at 8:30 in the morning. (Sgd.) MITCH MCDEERE

MOTION FOR LEAVE OF COURT TO FILE REPLY WITH MOTION TO ADMIT ATTACHED REPLY PETITIONER, by counsel, respectfully states that: [1] 1. Petitioner received a copy of respondents Comment to his petition on 3 January 2006. The Comment contains several allegations of fact and misinterpretations of the record that may mislead the court and need to be corrected. For this reason, petitioner intends to file a Reply. [2] 2. Under existing rules, a Reply can no longer be filed as a matter of course. Consequently, petitioner seeks leave of this Court to file the said Reply, a copy of which, pursuant to the 1997 Rules on Civil Procedure, is attached to this motion. [3] WHEREFORE, petitioner respectfully prays that he be granted leave of court to file a Reply and for the Court to admit the attached Reply. Quezon City for Manila; 5 January 2007. (Sgd.) ATTICUS FINCH Counsel for the Petitioner [Address] PLUS: 1. 2. [4] Request for and Notice of Hearing [5] Explanation for service by registered mail

3.

Motion for judgment on the pleadings Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39, Quezon City

[1] 1. On 1 June 2006, defendant submitted her Answer to the Complaint, thereby causing the issues to be joined. [2] 2. This case is, thus, ripe for pre-trial. Complying with Rule 18, Section 1 of the 1997 Rules on Civil Procedure, plaintiff respectfully asks that this case be set for pre-trial. [3] WHEREFORE, plaintiff respectfully prays that this case be set for pre-trial on a date convenient to this Honorable Court. Civil Case No. Quezon City; 13 April 2007. (Sgd.) ATTICUS FINCH Counsel for the Plaintiff [Address] [4] REQUEST AND NOTICE

LAKISA LAYAW, Plaintiff, 97-31312 - versus LAKISA HIRAP, Defendant. x ------------------------- x MOTION FOR JUDGMENT ON THE PLEADINGS Plaintiiff, by counsel, respectfully states that: 1. On 6 July 2005, plaintiff sued defendant for a sum of money in the amount of Nine Hundred Thousand Pesos (P900,000.00). [1 & 2] 2. In his Answer, defendant admitted the obligation and merely stated that he was asking to be given an extension of time to pay his obligation but that plaintiff instead filed this Complaint. The Answer admits the material allegations of the Complaint and has not tendered any issue; consequently, a judgment on the pleadings may be rendered. [3] WHEREFORE, plaintiff respectfully prays a judgment on the pleadings be rendered in his favor. Quezon City; 13 April 2007. (Sgd.) ATTICUS FINCH Counsel for the Plaintiff [Address] PLUS: 1. 2. [4] Request for and Notice of Hearing [5] Proof of Service 4. Ex parte motion to set for pre-trial Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39, Quezon City LAKISA LAYAW, Plaintiff, 97-31312 Civil Case No. - versus For: Sum of Money

THE BRANCH CLERK OF COURT Regional Trial Court Branch 39, Quezon City Please submit the foregoing to the Court for its approval immediately upon receipt hereof. Copy furnished: MITCH MCDEERE, ESQ. 2 The Firm Laguna Street, Quezon City Please take notice that counsel has requested for the approval of the foregoing motion immediately upon receipt. (Sgd.) ATTICUS FINCH Counsel for the Plaintiff PLUS: [5] Proof of Service 5. Motion for postponement Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39, Quezon City DILA TORY, Plaintiff, 008877 - versus PASEN SYOSO, Defendant. x ------------------------- x MOTION FOR POSTPONEMENT PLAINTIFF, by counsel, respectfully states that: Civil Case No.

LAKISA HIRAP, Defendant. x ------------------------- x EX PARTE MOTION TO SET CASE FOR PRE-TRIAL PLAINTIFF, by counsel, respectfully states that:

1. This case is set for trial on 5 May 2007 at 8:30 in the morning. [1] 2. On said date and time, the undersigned counsel will be unable to appear before this Honorable Court as he has also been directed to appear on this date and time before the Regional Trial Court of Makati City, Branch 139 for People of the Philippines v. Bil Moko, Criminal Case No. 009988, where he is

scheduled to terminate cross-examination of the prosecutions expert witness who will be available only on said date and time. [2] 3. Without impugning the importance of these proceedings, plaintiff respectfully submits that his attendance in the Makati case becomes indispensable; otherwise, the accused in said case would be deprived of the opportunity to confront and cross-examine a vital witness against her. 4. This motion is prompted only by the foregoing reason and not for delay. [3] WHEREFORE, plaintiff respectfully prays that the trial scheduled on 5 May 2007 be POSTPONED to another date convenient to this Honorable Court. Quezon City; 13 April 2007. (Sgd.) MITCH MCDEERE Counsel for the Plaintiff [Address] PLUS: 1. 2. [4] Request for and Notice of Hearing [5] Proof of Service 6. Motion for extension of time Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39, Quezon City DILA TORY, Plaintiff, Case No. 008877 - versus PASEN SYOSO, Defendant. x ------------------------------------ x MOTION FOR EXTENSION OF TIME PLAINTIFF, by counsel, respectfully states that: 1. He has been directed to file a Reply to defendants Answer by 10 May 2007. [1 & 2] 2. The undersigned counsel, however, anticipates his inability to file the Reply on or before the said due date because of the tremendous pressure of other equally urgent professional work requiring the preparation of pleadings and almost daily trial appearances before the various courts within and outside Metro Manila. For this reason, the undersigned is constrained to ask for an additional fifteen (15) days from 10 May 2007, or until 25 May 2007, within which to submit plaintiffs Reply. 3. This motion is not intended for delay but is motivated only by the foregoing reason. [3] WHEREFORE, plaintiff respectfully prays that he be granted an additional fifteen (15) days from 10 May 2007, or until 25 May 2007, within which to submit plaintiffs Re ply. Quezon City; 13 April 2007. (Sgd.) MITCH MCDEERE Counsel for Plaintiff [Address] PLUS: Civil

1. 2.

[4] Request for and Notice of Hearing [5] Proof of Service 7. Motion to declare defendant in default Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39, Quezon City

ANAKIN SKYWALKER, Plaintiff, 000909 - versus PADME AMIDALA, Defendant. x ---------------------------------- x MOTION TO DECLARE DEFENDANT IN DEFAULT PLAINTIFF, by counsel, respectfully states that: 1. Plaintiff filed this Complaint against defendant on 1 March 2007; summons were served on defendant on 20 March 2007, as indicated by the Sheriffs Return of even date, a copy of which is attached as ANNEX A. [1 & 2] 2. Defendants reglementary period to file Answer ended on 5 April 2007; no motion for extension of such period was filed nor was any granted motu proprio by this Honorable Court. Despite the lapse of time, defendant has failed to answer the Complaint against her; plaintiff is entitled to a declaration of default and the right to present evidence ex parte against defendant. [3] WHEREFORE, plaintiff respectfully prays that defendant be declared in default and that plaintiff be allowed to present evidence ex parte before the Clerk of Court acting as Commissioner. Quezon City; 7 April 2007. (Sgd.) DARTH SIDIOUS Counsel for Plaintiff [Address] PLUS: 1. 2. [4] Request for and Notice of Hearing [5] Proof of Service Civil Case No.

8.

Motion to lift order of default Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 39, Quezon City

1. I am a member of the Triple X Village Homeowners Association (Association) and was formerly a Director and Corporate Secretary of the Association. [3] 2. I accuse and hereby charge MR. MA INGAY, residing at 5 Privet Drive, Triple X Village, Makati, of violating Article 358 of the Revised Penal Code (Slander and Oral Defamation), committed against me when he publicly, maliciously and deliberately uttered defamatory remarks against me during the Board Meeting of the Association on 27 January 2007. This is attested to by the following exchange that transpired between Mr. Ingay and the other members of the Board in attendance: Civil Case No. (Quote Exchange) Attached as ANNEX A is a copy of the official transcript of the meeting. 3. Prior resort to the Barangay conciliation system proved fruitless as Mr. Ingay did not retract his remarks. Consequently, a Certification to File Action was issued by the Barangay Chairperson, a copy of which is attached as ANNEX B.

ANAKIN SKYWALKER, 000909 - versus PADME AMIDALA,

Plaintiff,

Defendant. x ---------------------------------- x MOTION TO LIFT ORDER OF DEFAULT DEFENDANT, by counsel, respectfully states that: 1. Five (5) days after service of summons and receipt of Complaint, she filed a Motion to Dismiss on the ground that plaintiffs claim is outside the jurisdictional amount of this Honorable Court under the new Expanded Jurisdiction Act and that the Complaint should properly be filed and tried before the Metropolitan Trial Court. The Motion to Dismiss, which was received by plaintiffs counsel on 25 March 2007, was set for hearing on 10 April 2007, as indicated on the Request for and Notice of Hearing. 2. Without waiting for the hearing on the Motion to Dismiss, this Honorable Court declared defendant in default on 7 April 2007 based solely on plaintiffs Motion, filed two (2) days after the supposed lapse of the reglementary period, which, however, was tolled by the filing of a Motion to Dismiss. [1 & 2] 3. Under the circumstances, the order of default is premature and without legal and factual basis as: (a) defendant has not failed to file an Answer within the reglementary period, (b) the reglementary period has not lapsed because of the filing of the Motion to Dismiss within the period, and (c) the pendency of the Motion to Dismiss is prejudicial to the issue of defendants default. Consequently, the order of default should be lifted. [3] WHEREFORE, defendant respectfully prays that the Order of Default against her be LIFTED and that this Honorable Court resolve her Motion to Dismiss. Quezon City; 8 April 2007. (Sgd.) OBI WAN KENOBI Counsel for Defendant [Address] PLUS: 1. 2. II. [4] Request for and Notice of Hearing [5] Proof of Service PLEADINGS AND OTHER LEGAL FORMS IN CRIMINAL PROCEDURE A. Complaint-Affidavit and Counter-Affidavit 1. Complaint-Affidavit ) ) s.s. COMPLAINT-AFFIDAVIT [1] I, MA SELAN, of legal age, Filipino, with assistance of counsel, and [2] resident of 4 Privet Drive, Triple X Village, Makati, do hereby state under oath that:

4. There is no other person named Ma Selan residing at Triple X Village nor is there any other person named Ma Selan who has acted as Board Member of the Association. Consequently, Mr. Ingays public and defamatory utterance was clearly a reference to me and to no other. 5. Mr. Ma Ingays remarks, calling me a swindler twice over, uttered in a public meeting are clearly insulting and defamatory as they malign me and attribute to me a criminal act, nature and predisposition. There is, moreover, no doubt that Mr. Ingays use of the word swindled was deliberate as his explanation and clarification a few utterances thereafter would show. Mr. Ing ays remarks are also very serious as they cast aspersions on my reputation, character and very person before my peers and fellow homeowners. 6. Mr. Ingays remarks have injured my name, reputation and character before my neighbors and peers. While my name, reputation and character are incapable of pecuniary estimation as these are the result of a lifetimes effort to build a name, reputation and character th at my children and their children can be proud to bear, Mr. Ingay cannot be allowed to simply go scot-free without bearing the consequences of his acts. For this reason, I am also holding Mr. Ma Ingay liable civilly for defaming me in the amount of One Million Pesos (P1,000,000.00) in nominal damages, Five Hundred Thousand Pesos (P500,000.00) in moral damages and Five Hundred Thousand Pesos (P500,000.00) in exemplary damages. TO THE TRUTH OF THE FOREGOING, I have signed this Complaint-Affidavit on 13 April 2007. [4] (Sgd.) MA SELAN Complainant-Affiant [5] SUBSCRIBED AND SWORN TO BEFORE ME this 13th day of April 2007. (Sgd.) Investigating Prosecutor [6] CERTIFICATION I HEREBY CERTIFY THAT I HAVE PERSONALLY EXAMINED THE AFFIANT AND AM SATISFIED THAT HE VOLUNTARILY EXECUTED AND UNDERSTOOD HIS AFFIDAVIT. (Sgd.) Investigating Prosecutor

Republic of the Philippines City of Makati

2.

Counter-Affidavit ) ) s.s. COUNTER-AFFIDAVIT Re: I.S. No. 1613

Republic of the Philippines City of Makati

6. For this reason, it is certainly incomprehensible that I should stand accused of estafa by Ms. Gulang. I performed no act of deceit or fraud against her in ordering the units. I performed NO ACT that even remotely resembles ANY of the acts punished under Article 315 . If at all, any cause of action is PURELY CIVIL in nature and that liability does not pertain to my personal account in the absence of a showing that I benefited from the Nextel units (which Ms. Gulang does not even allege and cannot prove); any civil liability should pertain to the Office of the Mayor, not to me. 7. Considering the foregoing, I respectfully submit that there is no prima facie basis to conclude that the crime of Estafa or that any crime at all has been committed. The Complaint against me should, thus, be dismissed. TO THE TRUTH OF THE FOREGOING, I have signed this Statement on 3 February 2007. [4] (Sgd.) MA LABO Affiant PLUS: 1. 2.

[1] I, MA LABO, of legal age, with assistance of counsel, do hereby state under oath that: 1. I am the Chief of Staff of the Mayor of Quezon City, and have been occupying said post since his election to the post in 1998. In said capacity, I am in charge of coordinating the day-to-day affairs and activities of his Office. [2] 2. I recently learned that I have been made a respondent in I.S. No. 1613, a charge for estafa, filed by a certain MA GULANG on 19 January 2007 before the Office of the City Prosecutor for Quezon City. 3. The charge is based on a supposedly unpaid account for the purchase of seven (7) Nextel phone units by a Mr. MANGGA GANTSO of the Quezon City Rescue and Environmental Distress Unit, which made the Mayor their Honorary Chairman with no direct functions; he has been supporting their activities financially with voluntary contributions. [3] 4. There is no truth to the allegations in MA GULANGs complaint. There is no factual nor legal basis to charge me with estafa. The Complaint must be dismissed. To rebut and contradict MA GULANGs malicious lies, I set forth the true circumstances leading to the transaction below: 4.1. Sometime last year, Ms. Gulang called the office of the Mayor, looking for him; I informed her that he was not around. I took a message from her saying that she was a friend of the Mayor and that she was selling Nextel units and if we wanted to buy units from her. I informed her that both the Mayor and I had our units already; she then told me if the Mayor could refer her to prospective clients. When the Mayor arrived, I relayed the message to him. 4.2. Quite coincidentally, Mr. Gantso had called the Mayor asking if he could assist in securing Nextel units. The Mayor asked me to call Ms. Gulang. Mr. Gantso and Ms. Gulang were able to meet, as a result. 4.3. On that day, Ms. Gulang brought the units to the Mayors Office; she met with Mr. Gantso inside the Mayors office. They transacted business inside the Mayors Office and only passed by my office on their way out. 4.4. Some time after that, Ms. Gulang phoned me and told me that Mr. Gantso had not paid her the amount of P11,000.00 for the units. Somewhat embarrassed by this, I called Mr. Gantso and told him to pay Ms. Gulang; he assured me that he would pay her but that he just needed to collect money from the rest of the group. 4.5. After persistent calls from Ms. Gulang telling me that Mr. Gantso had not yet paid, I gave her the telephone number of Gantso so that she could just call him directly. But even then, I would still get calls from Ms. Gulang; and when she started to get angry over the telephone, I set up an appointment for Mr. Gantso to meet with her at the Office. 4.6. Thereafter, I would still receive phone calls telling me that Mr. Gantso had yet to pay; I would follow up with Mr. Gantso but he simply gave me this promise that he would pay. 5. It is utterly inexplicable that Ms. Gulang would hold me liable for estafa when all that I did was to refer Ms. Gulang to Mr. Gantso; to a certain extent, I even exerted my best efforts to see that Ms. Gulang was paid due simply to my great embarrassment at the prospect of being accused of referring a person who does not know how to pay for an obligation.

[5] Verification [6] Certification B. Information and Complaint 1. Information (with Certificate of Preliminary Investigation or Inquest) a. Bigamy (Caption)

PEOPLE OF THE PHILIPPINES, No. 00567 - versus PI KUTIN,

Plaintiff, Criminal Case For: Bigamy

Accused. x ---------------------------------------- x INFORMATION The Undersigned accuses PI KUTIN of the crime of Bigamy, committed as follows: That on or about 3 July 2006, in the City of Quezon and within the jurisdiction of this Honorable Court, the said accused, being then legally married to BIL MOKO, and without such marriage having been legally dissolved and thus valid and existing, did wilfully, unlawfully and felicitously contract a second marriage with ASA WA in the City of Quezon. CONTRARY TO LAW. ELLIOT NESS Assistant City Prosecutor CERTIFICATE OF PRELIMINARY INVESTIGATION I hereby certify that a preliminary investigation in this case was conducted by me in accordance with law; that I examined the Complainant and her witnesses; that there is reasonable ground to believe that the offense charged had been committed and that the accused is probably guilty thereof; that the accused was informed of the Complaint and of the evidence submitted against him and was given the opportunity to submit controverting evidence; and that the filing of this Information is with the prior authority and approval of the City Prosecutor.

ELLIOT NESS Assistant City Prosecutor SUBSCRIBED AND SWORN TO BEFORE ME this 9th day of August 2006 in Quezon City. AL CAPONE City Prosecutor

PEOPLE OF THE PHILIPPINES, Plaintiff, Criminal Case No. 00567 MAEL SIA, - versus For: Attempted Rape

Bail Recommended: P10,000.00 b. Theft

Accused. x --------------------------------------------- x INFORMATION The undersigned accuses MAEL SIA of attempted rape committed as follows: Criminal Case That on or about 6 June 2005, in Quezon City, the accused did then and there wilfully, unlawfully and feloniously enter the house of SEK SEE, a married woman, and finding that her husband was away, with lewd designs and by means of force and intimidation, commenced directly by overt acts to commit the crime of attempted rape upon her person, to wit: while SEK SEE was cooking lunch, the accused seized her from behind, threw her to the floor, raised her skirt, pulled down her underwear and attempted to penetrate her with his sexual organ and would have succeeded in doing so had not her loud protests and vigorous resistance brought her neighbors to her assistance, causing the accused to flee from the premises without completing all the acts of execution. CONTRARY TO LAW with the aggravating circumstance of dwelling. ELLIOT NESS Assistant City Prosecutor PLUS: Certification of Preliminary Investigation or Inquest d. Frustrated Murder (Caption) PEOPLE OF THE PHILIPPINES, Plaintiff, No. 00567 - versus MAMA MATAY, Accused. x --------------------------------------------- x INFORMATION The undersigned accuses MAMA MATAY of frustrated murder committed as follows: That on or about 21 August 2006, in Quezon City, the accused did then and there take a loaded .44 Caliber Magnum pistol, directly aim the same firearm at the person of VIC TIMA, an invalid septuagenarian, and, at point blank range, with intent to kill, discharge the firearm twice against the person of said Vic Tima, inflicting on said Vic Tima two (2) wounds on his chest and stomach, which wounds would have been fatal had not timely medical assistance been rendered to the said Vic Tima. CONTRARY TO LAW with the aggravating circumstances of Evident Premeditation, use of firearm and disregard of age. (Sgd.) ELLIOT NESS Assistant City Prosecutor

(Caption) PEOPLE OF THE PHILIPPINES, No. 00567 - versus KLEPTO MANIAC, Accused. x --------------------------------------------- x INFORMATION For: Theft Plaintiff,

The Undersigned accuses KLEPTO MANIAC of the crime of Theft, committed as follows: That on or about 3 July 2006, in the City of Quezon and within the jurisdiction of this Honorable Court, the said accused, then 11 years old and without any known address, willfully, unlawfully and feloniously, with intent to gain, without force upon things or violence upon persons and without the knowledge and consent of MA ALAHAS, the owner, took a gold necklace studded with diamonds valued at One Hundred Thousand Pesos (P100,000.00) to the prejudice of said owner. CONTRARY TO LAW. ELLIOT NESS Assistant City Prosecutor CERTIFICATION AS TO CONDUCT OF INQUEST I hereby certify that the accused was lawfully arrested without a warrant and that, upon being informed of his rights, refused to waive the provisions of Article 125 of the Revised Penal Code and, for this reason, an Inquest was conducted; that based on the complaint and the evidence presented before me without any countervailing evidence submitted by the accused, despite opportunity to do so, there is reasonable ground to believe that the accused has committed the crime of theft and should, thus, be held for said crime; that this Information was with the prior authority of the City Prosecutor. ELLIOT NESS Assistant City Prosecutor

Criminal Case For: Frustrated Murder

SUBSCRIBED AND SWORN TO BEFORE ME this 9th of August 2006 in Quezon City. AL CAPONE City Prosecutor c. Attempted Rape (Caption)

PLUS: Certification of Preliminary Investigation or Inquest C. Motions 1. Motion to Quash Information [1] Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 90, Quezon City Plaintiff, No. 00567 - versus KLEPTO MANIAC, Accused. x ------------------------------------------ x MOTION TO QUASH [2] THE ACCUSED, by counsel, respectfully moves to quash the Information for the crime of theft on the following: [3] GROUNDS 1. 2. IT CONTAINS AVERMENTS WHICH, IF TRUE, WOULD CONSTITUTE A LEGAL JUSTIFICATION; THIS COURT IS WITHOUT JURISDICTION. In support, the accused respectfully states that: ARGUMENT The Information alleges that the accused KLEPTO MANIAC is eleven (11) years old and without any known address. Under Article 12, paragraph 3 of the Revised Penal Code, a person over nine years of age and under fifteen, unless he acted with discernment, is exempt from criminal liability. There is no allegation that the accused acted with discernment. Even granting said discernment, the accused cannot be tried but instead proceeded against under Article 80 of the Revised Penal Code, which provides that a minor, unless sixteen years of age at the time of the commission of a grave or less grave felony, cannot be tried but instead shall have the benefit of a suspension of all proceedings against him. The duty of the court would be to commit the minor to the custody or care of a public or private benevolent or charitable institution for the care and education of homeless and delinquent children or to the custody of the Department of Social Work and Development. [4] WHEREFORE, it is respectfully prayed that the Information against the accused be QUASHED and that the accused be released immediately from detention. [5] Quezon City; 7 July 2007. [6] (Sgd.) MITCH MCDEERE Counsel for the Accused [Address] PLUS: 1. 2. [7] Request for and Notice of Hearing [8] Proof of Service 2. Motion to Quash Search Warrant For: Theft Criminal Case

PEOPLE OF THE PHILIPPINES, Plaintiff, - versus -

[1] (Caption)

Criminal Case No. 0002 2 For:

PEOPLE OF THE PHILIPPINES,

Libel VIG CHAN, Accused. x ---------------------------------------------- x MOTION TO QUASH SEARCH WARRANT The ACCUSED, by counsel, respectfully moves for the quashal of Search Warrant No. 1122 issued by this Honorable Court on and dated 12 July 2006 based on the following considerations: [2] 1. Rule 126, Sec. 10 or the Revised Rules of Court provides expressly that a search warrant shall be valid for ten (10) days from its date and that thereafter, it shall be void. 2. Search Warrant No. 1122 is dated 12 July 2006. It was served on the accused on 23 July 2006, the 11th day from its date; this is certified to by the Sworn Inventory and Return executed by Major Alang Alam, the leader of the searching team (a copy of which is already part of the records). A search was made on the same day, 23 July 2006; pursuant to said search, certain objects were seized and delivered to the court. Under the law, the Search Warrant is void and must, thus, be quashed. [3] WHEREFORE, it is respectfully prayed that Search Warrant No. 1122 be QUASHED and all objects seized under its purported authority be declared INADMISSIBLE under the exclusionary rule in Article III, Section 3(2) in relation to section 2 of the 1987 Constitution. [4] Quezon City; 25 July 2006. [5] (Sgd.) MA TAPANG Counsel for Accused [Address] PLUS: 1. 2. [6] Request for and Notice of Hearing [7] Proof of Service 3. Motion to Suppress Evidence [1] (Caption) PEOPLE OF THE PHILIPPINES, - versus VIG CHAN, Accused. x ---------------------------------------------- x MOTION TO SUPPRESS EVIDENCE UNLAWFULLY SEIZED The ACCUSED, by counsel, respectfully moves for the suppression of objects seized on 23 July 2006, pursuant to Search Warrant No. 1122 issued by this Honorable Court dated 12 July 2006, based on the following considerations: [2] 1. Search Warrant No. 1122 was served on the 11th day and is, thus, void. Plaintiff, Criminal Case No. 00022 For: Libel

2. The motor vehicle seized does not fall within the property that may lawfully be seized. Discussion [1] Search Warrant No. 1122 was served on the 11th day and is, thus, void. 1. Rule 126, Sec. 10 of the Revised Rules of Court provides expressly that a search warrant shall be valid for ten (10) days from its date and that thereafter, it shall be void. 2. Search Warrant No. 1122 is dated 12 July 2006. It was served on the accused on 23 July 2006, the 11th day from its date; this is certified to by the Sworn Inventory and Return executed by Major Alang Alam, the leader of the searching team (a copy of which is already part of the records). A search was made on the same day, 23 July 2006; pursuant to said search, certain objects were seized and delivered to the court. Under the law, the Search Warrant is void. 3. No valid seizure may be made under a void warrant. For this reason, the following objects must be suppressed: [list items] [2] The motor vehicle seized does not fall within the property that may lawfully be seized. 4. On the occasion of the search, the searching party also seized accuseds green Jaguar XJE with license plate, No. 1", allegedly for being subject of the offense. Thereafter, it was impounded and kept at the PNP Motor Pool. 5. The motor vehicle cannot be subject of the offense as accused is charged with libel. There is no relation between the motor vehicle and libel. 6. Moreover, the motor vehicle is not mala prohibita that would justify a seizure thereof; neither could there be a seizure of evidence in plain view. [3] WHEREFORE, it is respectfully prayed that all objects seized under the void Search Warrant No. 1122 be declared INADMISSIBLE under the exclusionary rule in Article III, section 3(2) in relation to Section 2 of the 1987 Constitution. Furthermore, it is prayed that the Green Jaguar XJE with license plate No. 1" be immediately returned to the accused. [4] Quezon City; 25 July 2006. [5] (Sgd.) MA TAPANG Counsel for Accused [Address] PLUS: 1. 2. [6] Request for and Notice of Hearing [7] Proof of Service 4. Motion for Bail [1] (Caption) PEOPLE OF THE PHILIPPINES, Plaintiff, No. 00567 - versus NAKA PIIT, Accused. x ------------------------------------------ x Criminal Case For: Murder PLUS: Request for and Notice of Hearing D. Application for Bail

MOTION FOR BAIL [2] THE ACCUSED, by counsel, respectfully moves to be allowed bail on the ground that the [3] prosecutions evidence of his guilt is not strong. In support, he respectfully submits the following: 1. The Information alleges that he raped the private complainant on 25 December 2005 at his residence in Quezon City. The prosecutions own evidence, however, belies this allegation as: (a) the medical certificate (attached as ANNEX A to the Information) states that private complainant is in a virgin state with no physical and outward signs of trauma; (b) the medical certificate issued by the NBI doctor (attached as ANNEX B to the Information) after a physical examination of the accused, two (2) days after the alleged rape, shows that he is suffering from erectile dysfunction and has been so afflicted for close to five (5) years now and (c) the sworn statements of the private complainant conflict with and contradict each other such that her credibility must be placed in doubt. 2. For these reasons, there is no basis to conclude that the accused raped the private complainant as there is less than circumstantial evidence of this fact. He is, thus, entitled to bail as a matter of right. WHEREFORE, it is respectfully prayed that the accused be granted: (1) a bail hearing, during which the prosecution should be directed to present its evidence to show the strength of its evidence of the accuseds guilt, and (2) thereafter, grant the accused reasonable bail. Other just and equitable reliefs are also prayed for. Quezon City; 7 July 2007. (Sgd.) MITCH MCDEERE Counsel for the Accused [Address]

[1] (Caption) PEOPLE OF THE PHILIPPINES, Plaintiff, - versus RECY DIVIST, Accused. x ---------------------------------------------- x APPLICATION FOR PROBATION THE ACCUSED, by counsel, respectfully applies for probation pursuant to the provisions of Presidential Decree No. 968, as amended. In support of this application, the accused respectfully submits the following: 1. Accused-applicant is of legal age and currently gainfully employed at ASN Broadcasting Corporation located at Timog Avenue, Quezon City. On 23 February 2007, she pleaded guilty to the off ense charged herein; consequently, this Honorable Court in its Order dated 8 March 2007 sentenced accusedapplicant to an indeterminate penalty ranging from three (3) years to five (5) years of prision correccional. [2] 2. Accused-applicant humbly submits that she possesses all the qualifications and none of the disqualifications enumerated under section 2 of Presidential Decree No. 968, specifically: 2.1. She has not been convicted of any crime against national security or public order; Criminal Case No. 114878

2.2. She has not been previously convicted by final judgment of an offense punishable by imprisonment of not less than one (1) month and one (1) day and/or a fine of not less than Two Hundred Pesos (P200.00); 2.3. She has not previously applied for nor had been previously placed under probation under Presidential Decree No. 968. 2.4. She has not started to serve her sentence and, to date, has not filed any Notice of Appeal from the Order of conviction. 3 Finally, granting this application will not in any way depreciate the seriousness of the offense charged nor cause any undue risk that during the period of probation, accused-applicant will commit another crime. Moreover, accused-applicant does not need any correctional treatment requiring commitment to an institution. [3] WHEREFORE, accused-applicant respectfully prays that her application for probation be GRANTED and that she be placed under probation under such terms and conditions necessary to attain and ensure the objectives of the law and which, under the circumstances, are fair, just and reasonable in the sound discretion of this Honorable Court. Quezon City for Pasig City; 12 March 2007. (Sgd.) ATTICUS FINCH Counsel for Accused [Address] PLUS: 1. 2. [4] Verification [5] Request for and Notice of Hearing