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The accused, Emiliano Kho, through his counsel, filed a Motion for Production and Inspection of Documents with the Sandiganbayan court. The motion requests that the prosecution produce and allow the defense to inspect and copy 5 documents related to the criminal case against the accused, including complaint letters and checks. The defense argues this is needed to prevent evidence tampering and to adequately prepare a defense. A hearing on the motion is requested for February 27, 2017 at 8:30am. Copies were served on the prosecution through registered mail.
Originalbeschreibung:
This is a Sample Motion for Production and Inspection of Documents, as provided for in the Rules of Court.
The accused, Emiliano Kho, through his counsel, filed a Motion for Production and Inspection of Documents with the Sandiganbayan court. The motion requests that the prosecution produce and allow the defense to inspect and copy 5 documents related to the criminal case against the accused, including complaint letters and checks. The defense argues this is needed to prevent evidence tampering and to adequately prepare a defense. A hearing on the motion is requested for February 27, 2017 at 8:30am. Copies were served on the prosecution through registered mail.
The accused, Emiliano Kho, through his counsel, filed a Motion for Production and Inspection of Documents with the Sandiganbayan court. The motion requests that the prosecution produce and allow the defense to inspect and copy 5 documents related to the criminal case against the accused, including complaint letters and checks. The defense argues this is needed to prevent evidence tampering and to adequately prepare a defense. A hearing on the motion is requested for February 27, 2017 at 8:30am. Copies were served on the prosecution through registered mail.
Comes now accused EMILIANO S. KHO, by counsel, respectfully
moving for an order requiring plaintiff PEOPLE OF THE PHILIPPINES:
1. To produce and permit defendant to inspect and to copy each of
the following documents:
Letter-Complaint dated June 20, 2016 of private
complainants Anita O. Paz and Romulo C. Ozaeta Supplementary Letter-Complaint dated July 4, 2016 of private complainant Romulo C. Ozaeta Handwritten “Kasunduan” dated August 21, 2015 allegedly executed between accused Emiliano S. Kho and Dorcas Mining Corporation Chinabank Congressional Branch Check No. 189452 dated November 2, 2015 in the amount of Php 250,000.00 Chinabank Congressional Branch Check No. 190834 dated December 3, 2015 in the amount of Php 750,839.22
2. Plaintiff has the possession, custody or control of each of the
foregoing documents and objects. Each of them constitutes or contains evidence relevant and material to the matter involved in this criminal case. 3. Said copies of the above-mentioned documents are urgently needed in order to prevent unnecessary alteration and suppression of records on the part of the prosecution and to justifiably allow the defense to sufficiently prepare its counter-allegations against said complainant. EMILIANO KHO y SANDOVAL et al., Crim. Case No. SB-16-CRM-2091
Page 2 of 3
4. This motion is made pursuant to Section 10 of Rule 116 of the
1997 Revised Rules of Criminal Procedure.
Respectfully given this 13th day of January 2017, Quezon City,
Philippines.
ATTY. JAMES EARL REYES
Counsel for Accused Roll No. 32789 IBP. Receipt No. 379423/2-7-2016 MCLE Compliance No. V-31400
REQUEST FOR HEARING
THE DIVISION CLERK OF COURT
SANDIGANBAYAN Second Division Quezon City
Greetings!
Please submit the foregoing Motion to the Court for its
consideration and approval immediately upon receipt hereof and kindly include the same in the court’s calendar for hearing on Friday, 27 February 2017 at 8:30 in the morning.
ATTY. JAMES EARL REYES
Counsel for Accused Roll No. 32789 IBP. Receipt No. 379423/2-7-2016 MCLE Compliance No. V-31400
Copy furnished:
Deputy Special Prosecutor Atty. Natividad E. Santos
OFFICE OF THE SPECIAL PROSECUTOR 4th Floor Ombudsman Building Agham Road, Quezon City EMILIANO KHO y SANDOVAL et al., Crim. Case No. SB-16-CRM-2091
Page 3 of 3
Copies of the foregoing Motion for Production and Inspection
of Documents have been served through registered mail due to lack of personnel for personal service. Please take notice that counsel has requested to be heard on 27 February 2017 at 8:30 in the morning.
ATTY. JAMES EARL REYES
Counsel for Accused Roll No. 32789 IBP. Receipt No. 379423/2-7-2016 MCLE Compliance No. V-31400