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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


First Judicial Region
San Fernando City, La Union
Branch ____,

PEOPLE OF THE PHILIPPINES,


Plaintiff, CRIMINAL CASE NO. ____________
For: Murder

-Versus

BENEDICT JULATON,
Accused.

X-------------------------------------------X

URGENT EX-PARTE MOTION TO ALLOW ACCUSED TO


ATTEND WAKE AND BURIAL OF HIS BROTHERS

The accused, by counsel, to this Honorable Court, respectfully states


that:

1. That the accused lost two brothers, Benjie Julaton and Bernabe Julaton,
Jr., during a police operation on October 12, 2016 under highly
suspicious circumstances, when they were illegally arrested on that same
date;

2. That the accused is presently detained at the La Union Provincial Jail in


San Fernando City, La Union; and

3. That the accused wishes to attend the wake and burial of his brothers to
pay his last respects to them.

PRAYER

WHEREFORE, it is respectfully prayed of this Honorable Court that the


accused-movant, on humanitarian grounds, be allowed to attend the wake of
his brothers on June 26, 2016 at their residence at Bacnotan, La Union, and
their burial on June 27, 2016 at their hometown of Bacnotan, La Union.

Other just and equitable reliefs are likewise prayed for.

Baguio City for San Fernando City, La Union, October 24, 2016.
LOUIE L. SANTOS
Counsel for the accused
Attorneys Roll No. 66431, June 22, 2016
IBP No. 1041883, June 6, 2016, Baguio City
PTR No. 2713652, August 11, 2016, Baguio City
Rm.307, Jose Miguel Bldg.,
Labsan Street, Baguio City
Contact No.: 09286571527

NOTICE AND COPY FURNISHED:

THE BRANCH CLERK OF COURT


Regional Trial Court
San Fernando City, La Union, Branch ____

THE HONORABLE PROVINCIAL PROSECUTOR


Office of the Provincial Prosecutor
San Fernando City, La Union

Greetings:

Please take notice that the foregoing Motion will be submitted for the
Courts consideration and resolution on October 25, 2016 at 8:30 a.m. or as
soon thereafter as matter and counsel may be heard.

ATTY. LOUIE L. SANTOS

THE BRANCH CLERK OF COURT


Regional Trial Court
San Fernando City, La Union, Branch ____

THE HONORABLE PROVINCIAL PROSECUTOR


Office of the Provincial Prosecutor
San Fernando City, La Union