REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
QUEZON CITY
BRANCH 1
PEOPLE OF THE PHILIPPINES
CRIM. CASE NO.
08-203040
-versusJOHN DOE
Accused.
x----------------------------------------------------x

MOTION FOR LEAVE TO TRAVEL

ABROAD
COMES NOW the undersigned counsel for the accused
in the above-entitled case, respectfully moves this Honorable
Court for permission to travel abroad for business purposes
and in support thereof states:
1. That in an Order dated February 3, 2009 this
Honorable Court granted the private complainants Motion
for Issuance of Hold Departure Order against the accused;
2. That on November 5, 2009, the accused and the
private complainant entered into a Compromise Agreement,
which was approved by the Honorable Court on November
19, 2009;
3. That the accused has been diagnosed with Stage 3B
colon cancer;
4. That the accused to seek medical treatment in New
York, U.S.A.;
5. That in view of the above urgent health concerns,
the accused is necessitated to travel abroad for a period of
FIFTEEN (15) DAYS only from March 1-15, 2010;
6.
That the accuseds medical certificate, flight
schedules and hotel accommodations are detailed in the
itinerary prepared by the travel agency, hereto attached as
Annexes 1 , 2, 3, and 4 respectively;

7. That the accused has been fully compliant with his

obligations under the said Compromise Agreement, and he is
bent on complying faithfully with all the conditions specified
therein;
8. That the accused is not a flight risk. The above
requested travel is necessary for his immediate medical
treatment, and he will return to the country as scheduled on
March 15, 2010.

P R AY E R
WHEREFORE, premises considered, it is respectfully
prayed on this Honorable Court to grant this motion to allow
the accused to travel abroad solely for business purposes.
Other just and equitable reliefs are likewise prayed for.
RESPECTFULLY SUBMITTED.
Quezon City, February 10, 2010.

MEEZ CONGENIALY TY
Counsel for the Accused
PTR No.112345; Pasig City; 3 January
2010
IBP No. 23456; Pasig City; 5 January
2010
Attorney Roll No. 34567
MCLE Compliance III No. 0001111
123 Ditona Street
Pasig City
Telefax: (02) 666-6660
e-mail: congee@yey.com

NOTICE OF HEARING
THE CLERK OF COURT
Regional Trial Court
Branch 1, Quezon City
Assistant City Prosecutor AL CAPON
Office of the City Prosecutor
Quezon City Hall
Atty. Gringo Poe
Counsel for the Private Complainant

Rm 55, The Round Table

Quezon City

G R E E T I N G S:
Please take notice that the undersigned shall submit
the foregoing motion for the kind consideration and approval
of this Honorable Court on February 19, 2010 at 8:30 in the
morning as counsel shall be heard.

MEEZ CONGENIALY TY

Copy Furnished:
Assistant City Prosecutor AL CAPON
Office of the City Prosecutor
Quezon City Hall
Atty. Gringo Poe
Counsel for the Private Complainant
Rm 55, The Round Table
Quezon City

Explanation
The undersigned counsel informs the Honorable Court
that copy of the foregoing motion was served upon the
above-named counsel by registered mail due to distance and
time constraints, and unavailability of messenger to effect
personal service.
MEEZ CONGENIALY TY