Motion To Visit-gano.docx

Republic of the Philippines REGIONAL TRIAL COURT Second Judicial Region Branch 14 Lagawe, Ifugao PEOPLE OF THE PHILIPPINES, Plaintiff,

CRIM. CASE NO. 2475 For:

-versusJEFFREY WILSON B. GANO Accused. x------------------------------------x

RECKLESS IMPRUDENCE RESULTING IN SLIGHT PHYSICAL INJURY IN RELATION TO RA 7610

MOTION WITH UTMOST RESPECT, the accused, through undersigned counsel, most respectfully submits this motion and hereby states that: 1.

2.

The accused was charged with attempted reckless imprudence resulting in slight physical injuries in relation to RA 7610 and is presently detained at the BJMP District Jail at Tiger Hill, Baguinge, Kiangan, Ifugao; The family of the accused intends to perform a native ritual for the physical and mental well being of the accused called ‘pahang’ which requires the presence of the accused at their house;

PRAYER WHEREFORE, accused through undersigned counsel respectfully prays of this Honorable Court to allow accused to be at their house at Ingguiling, Lagawe, Ifugao on July 1, 2017 at 8:00 o’clock in the morning until 3:00 o’clock in the afternoon for the performance of said ritual. Other reliefs just and equitable are likewise prayed for. Respectfully submitted this 30th day of June 2017 at Lagawe, Ifugao, Philippines. PUBLIC ATTORNEY’S OFFICE Department of Justice By:

ATTY. DENNIS B. DIMALNAT Public Attorney II

THE CLERK OF COURT REGIONAL TRIAL COURT Branch 14 Lagawe, Ifugao GREETINGS: Please submit the foregoing motion for the kind consideration of the Honorable Court immediately upon receipt hereof. ATTY. DENNIS B. DIMALNAT Copy Furnished: Hilario Ronson H. Tilan Deputy Provincial Prosecutor Office of the Provincial Prosecutor Lagawe, Ifugao