DEPARTMENT OF JUSTICE

OFFICE OF THE CITY PROSECUTOR

PARAAQUE CITY

FRESHEVER INCORPORATED
Represented by: CHRISTER BRIAN
DEL ROSARIO
Complainant.
-versus- I.S No.XV-12-
INV-15-G-01619
For: Estafa and
Violation of B.P.22
FRANCIS JUAN
Respondent.
X- - - - - - - - - - - -X

MOTION
(For Leave to Rectify/Correct
The Annex to Our Opposition)

COMES NOW, the Complainant in the above-

entitled case by and through Undersigned Counsel
and unto this Honorable Prosecutor Office, most
respectfully avers:

1.That on September 14, 2015 the Complainant

through counsel submit Opposition to the
Motion of the Respondent to Admit Counter-
Affidavit.
2.That in the Opposition, the complainant
alleged that the said Counter- Affidavit
attached in the respondent Motion is a
MISTAKE, NOT A PARTY IN THIS CASE, that
herein respondent still failed to submits its
Counter-Affidavit.
 3.That the complainant humbly asking the
Honorable Office to rectify/correct the
annex attached in the opposition submitted.
4.That the copy of the said respondent Motion
to Admit Respondent Counter-Affidavit be
attached as Annex A
5.That the Complainant prays that leave be
Granted unto the Complainant Opposition to
the Motion to Admit Respondent Counter-
Affidavit.

P R A Y E R
WHEREFORE, it is most respectfully prayed
of this Honorable Prosecutors Office that the
Motion For leave to rectify/correct the annex of
the Opposition to the above-entitled case be
admitted.

All other reliefs, just and equitable

under the premises, are likewise prayed for.

City of Manila for Paranaque September 30,

2015.

ATTY. LEOPOLDO P. DELA ROSA

Counsel for the Complainant
Suite 307 CCI Building
1091 Concepcion Street
Ermita, Manila
IBP No. 974764/Manila/ 09-11-14
PTR No. 3827412/Manila/12-29-14
Roll No. 28195
MCLE Compliance No. IV-0020667
June 13, 2013

NOTICE
HON. ACP AMERHASSAN C. PAUDAC
City Prosecutor
 Office of the City Prosecutor
Paranaque City

FRANCIS JUAN
C/O PIER 1 BAR & GRILL HOLDINGS CORP.
Cabrera Road, Kaytikling,
Brgy. Dolores, Taytay, Rizal

Greetings

Please take Notice that Undersigned will submit the forgoing

Motion for the kind consideration and approval of the Honorable
Investigating Prosecutor, immediately upon receipt hereof.

ATTY. LEOPOLDO P. DELA ROSA

EXPLANATION
This is to certify as an Officer of the Court that a copy of this
Motion was served, not by personal service but by registered mail as
herein-below indicated by reason of time, distance, lack of manpower
and urgency.

ATTY. LEOPOLDO P. DELA ROSA

Copy furnished:

FRANCIS JUAN
C/O PIER 1 BAR & GRILL HOLDINGS CORP.
Cabrera Road, Kaytikling,
Brgy. Dolores, Taytay, Rizal

Cc//macel