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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
Quezon City

CHERRYLYN S. BANSILOY,
Complainant,
I.S. No. _________________
- Versus -
For: Violation of B.P. Blg. 22

Assigned to Hon. ACP__________________________

ANTHONY DELA CRUZ,
Respondent.
X * * * * * * * * * X

MOTION FOR LEAVE TO

REOPEN THE CASE

COMES NOW, the Respondent, in the above-entitled case, by

and through the Undersigned Counsel and unto this Honorable
Investigating Prosecutor, most respectfully submit this Motion for
Leave to Reopen the Case and in support thereof, most respectfully
avers:

1. That the instant case was deemed submitted for Resolution

without the respondent having filed his Counter-Affidavit owing to the
fact that he had a hard and difficult time and effort to search for
pertinent papers evidencing payment of the checks in question;

2. That respondent also needed reasonable time to intelligibly

meet and answer the allegations in the subject Complaint-Affidavit of
the case;

3. That in the broadest interest of substantial justice and

precepts of due process, respondent seeks leave that the instant
case be Re-opened and that his Counter Affidavit attached herewith
be admitted to form part of the records and be considered in the
resolution of the case.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of the Honorable Investigating Prosecutor of the case that;

a. This Motion be given its due weight and credence;

b. That the instant case be re-opened;

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c. That Respondent’s Counter Affidavit attached herewith be

admitted to form part of the records and be considered in the
resolution of the case.

Other relief and remedies just and equitable under the

premises are likewise prayed for.

Quezon City, Philippines, November _____, 2016.

ANTHONY DELA CRUZ

No. 1948 C.M Araullo Street
Sta. Mesa, Manila

N O T I C E

CHERRYLYN S. BANCILOY
No. 601 Isabel Tower, Tower 11 J. Jimenez Street
Kristong Hari, Quezon City

Greetings.

Please take notice that Undersigned will submit the foregoing Motion for
the kind consideration and approval of the Honorable Investigating Prosecutor,
immediately upon receipt hereof.

ANTHONY DELA CRUZ

EXPLANAT IO N

This is to certify 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.

ANTHONY DELA CRUZ

Copy furnished:

CHERRYLYN S. BANCILOY
No. 601 Isabel Tower, Tower 11 J. Jimenez Street
Kristong Hari, Quezon City

OFFICE OF THE CITY PROSECUTOR

Quezon City