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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
CITY OF MANILA
ROSARIO MENDOZA
Complainant
-versus-

XV-03-INV-15D-04547
For: B.P 22 and Estafa

MANUEL AJ PANGILINAN
Respondent
X- - - -- - - - - - - - - - - - -X
MOTION TO REOPEN AND LEAVE TO ADMIT
COPY OF EVIDENCE OF THE COMPLAINT
COMES NOW, the Complainant, in the above-entitled
case, by and through the Undersigned Counsel and unto this
Honorable office, most respectfully avers:
1. That the instant case was deemed submitted for resolution
on July 7,2015:
2. That upon reviewing

the

complaint

affidavit

the

complainant noticed that the annexes of the complaint not


attached in the complaint.
3. That there is a paramount need and necessity that the
case be Reopened and that the Annexes of the ComplaintAffidavit

attached herewith be Admitted before the

Honorable Investigating Prosecutor so that the case


records may truly bear out the real complaint in the case
and for an orderly investigation and resolution of the case
4. That this motion is not intended to delay the proceedings
and early disposition of the case.

WHEREFORE,

premises
respectfully prayed of the
Prosecutor of the case that:

considered,
Honorable

it is most
Investigating

a.

This Motion be given its due weight and credence;

b.

That the instant case be Re-opened;

c.

The evidence herewith be admitted so that the case


records may truly bear out the real complainant in the
case and for an orderly investigation and resolution of
the case.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.
City of Manila for Quezon City October 19, 2014.

ATTY. LEOPOLDO P. DELA ROSA


Counsel for the Private Complainant
Suite 307 CCI Building
1091 Concepcion Street
Ermita, Manila
PTR No. 3824412/Mla./ 12-29-2014
IBP No. 974764 /Mla/ 09-11-2014 to 2016
Roll No. 28195
MCLE Compliance No. IV-0020667
June 13, 2013

N O T I C E
MANUEL AJ PANGILINAN
#28 Clubhouse Drive
Capitol Gold Townhomes
Quezon City
Greetings.
Please take notice that Undersigned Counsel will submit the
foregoing 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


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:

MANUEL AJ PANGILINAN
#28 Clubhouse Drive
Capitol Gold Townhomes
Quezon City

Cc//macel