Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 2
Tagum City, Davao del Norte
JUAN DELA CRUZ,
Defendant,
FOR:

VIOL.

OF

R.A.

10591
-versusPEDRO SANTOS,
Respondent.
x--------------------------------------------x
DEFENDANTS MOTION TO APPEAR TELEPHONICALLY
OR VIA VIDEO CONFERENCE
COMES NOW Defendant, (hereinafter Defendant), by
and through her counsel, and requests permission from this
Honorable Court to appear telephonically or via video
conference for the hearing scheduled on December 15, 2016
because defendant is currently in an immigration detention
facility and is therefore unable to appear in person on the
specified hearing date.
In support of this motion, defendant states as follows:
1. The parties hearing is on December 15, 2016;
2. Defendant was detained on November 1, 2016;
3. Defendant will be accessible via telephone or
videoconference on December 15, 2016; and
4. Defendant requested permission to attend
hearing in person and the request was denied by
detention facility, therefore defendant requests
appear via telephone or video conference
December 15, 2016, the date of the hearing.

the
the
to
on,

Wherefore, the defendant respectfully requests:

1. That defendant be permitted to appear telephonically
or via video conference on December 15, 2016.
2. That this Court grant any such other relief this Court
deems just, equitable and proper.

Respectfully Submitted.
NOTICE OF SUBMISSION
THE CLERK OF COURT
RTC, Branch 2
Tagum City, Davao del Norte
Greetings!
Please submit the foregoing Motion Appear Telephonically or
via Video Conference for approval of this Honorable Court on
___________________.

SAMUEL DAVE O. SOLAS

COUNSEL FOR THE DEFENDANT
Roll No. 78965; 05-04-20015;
IBP O. R. No.(for C.Y. 2016) 957979; 12-15-15; Tagum City
PTR No. 1676543; 01-05-2015; Tagum City
MCLE COMPLIANCE NO.IV-0000888; November 9, 2016
Rm. 2, Arellano Street
Tagum City, Davao del Norte, Philippines
Tel No. (084) 400-4754
Cellular Phone Number: 0926-1237452

Copy furnished:
PROS. MARY JUSTICE P. AURELIO
PROVINCIAL PROSECUTION OFFICE
Hall of Justice, Tagum City
Reg. Receipt No.: _________
Date mailed: _____________

CERTIFICATE OF SERVICE
This is to certify that a copy of this Motion was served
to the Provincial Prosecutor, via registered mail due to the
distance of their offices from the office of the undersigned

and is definitely more expensive if done thru personal

service.

SAMUEL DAVE O. SOLAS