REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

____ JUDICIAL REGION
BRANCH __, ____ CITY

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus -
CRIMINAL CASE No.__
For: Frustrated Murder

Juan Berto,
Accused.

x -------------------------------x

URGENT MOTION
FOR ISSUANCE OF HOLD DEPARTURE ORDER

COMES NOW, the plaintiff, by undersigned private counsel with the conformity of
the public prosecutor and unto this Honorable Court, respectfully moves for
issuance of a Hold Departure Order (HDO) against the accused, and alleges that:

1) The accused has applied for employment abroad in an employment agency in

Cubao, Quezon City, and such application is now currently under process. Copies of
accused’s application form and his resume submitted to said agency are hereto
attached as Annexes “A” and “B” respectively;

2) The accused has used, and is currently using, the name Juan Pedro in his
application where in fact his real name is Juan Berto;

3) In adopting an alias, the accused’s act of applying for an employment abroad is

definitely regarded as being done in bad faith considering that a criminal case
against him is pending before this Honorable Court;

4) The application is done for the purpose of absconding and thereby evading
prosecution for his offense;

5) A Watch List Order (WLO) against the accused has already been issued by the
Department of Justice (DOJ) upon application of the plaintiff. Copy thereof is hereto
attached as Annex “C”;

6) Preventing the accused from leaving the country is proper considering that the
crime charged against him is a serious offense;
7) All precautions should be observed to ensure proper dispensation of justice.

WHEREFORE, premises considered, it is respectfully prayed that a Hold departure

Order be immediately issued against the accused.

Quezon City, Philippines, 13 January 2011.

Atty. ____________________
Private Counsel for Plaintiff

PTR No. _________; (date); Q.C.

IBP Lifetime No. _______; (date)
Roll of Attorneys No. _________
Address: __________________
Mobile No. _________________
Email: ____________________

CONFORME:

___(Name)________
Public Prosecutor

NOTICE OF HEARING

Atty. _____________
Counsel for the Accused
Address:___________

GREETINGS:

Please take notice that the foregoing Urgent Motion for Issuance of Hold Departure
Order shall be submitted for the consideration and approval of the Honorable Court
on Friday, January 21, 2011, at 2:00 p.m. or as soon as counsel and matter may be
heard.

_______(Name of Counsel for Movant)_______

EXPLANATION OF SERVICE

The above Urgent Motion for Issuance of Hold Departure Order was not served
personally to respondent/counsel for respondent and service by registered mail
was resorted to due to distance and lack of the undersigned’s personnel thereby
rendering personal service thereof inconvenient and impracticable.

________(Name of Counsel for Movant)_______

COPY FURNISHED:

Atty. ___________
Counsel for Accused
Address :