Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 217
Quezon City

PEOPLE OF THE PHILIPPINES,

Complainant, Crim. Cases No.11323-4CR
For: Syndicated Estafa
- versus -

ATTY. ALFEO DATINGUINOO

VIVAS, ATTY. MARGARITO C.
VILLARDO, ATTY LEONICIA
BALUALUA GARDUQUE,
ALDRIN NAVARRO VIVAS,
CECILLE UMALI, SIXTO
TARDECILLA, JR., and
SEVERAL JOHN and JANE
DOES,
Accused.
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EX-PARTE MOTION FOR FURLOUGH

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ACCUSED ATTY. ALFEO DATINGUINOO VIVAS, by himself,

unto to this Honorable Court respectfully submits files this Motion to ask for
permission for a one-day furlough each for the coming holidays, Christmas
and New Year, subject to the usual security measures that may be imposed,
and aver:

1. In today’s hearing and after the conclusion of the arraignment

proceeding, the Honorable Court inquired if there are matters still to be
discussed and Accused expressed his desire to request for a holiday furlough
just like what he did last year.

2. This request is for family reasons as well as humanitarian

considerations since Accused has been in detention since January 2016.

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 3. The Honorable Court has previously allowed Accused to go on
furlough during the 2017 Xmas and New Year’s Holidays last year subject
to appropriate security measures for a detainee.

4. During the furlough, Accused will be staying at Prince Plaza 2,

with address at De La Rosa Street cor. Legaspi Street, Legaspi Village,
Makati City.

5. If approved and availed of, the Xmas and New Year furloughs
will start at 12:00 noon, the departure time for Prince Plaza from Kamuning
Police Station, on December 24, 2018 and December 31, 2018 and end on
12:00 noon of December 25, 2018 and January 1, 2019 respectively with a
return trip back to Kamuning Police Station..

6. Accused will always be accompanied by police escort/s for the

whole duration of the furlough and/or to such measures that the Court may
imposes.

7. For the kind consideration of the Honorable Court.

ALFEO D. VIVAS

EXPLANATION

The above motion will be served to the Assistant City Prosecutor

handling the case for his concurrence.

ALFEO D. VIVAS

Copy furnished:

ACP PATRICK DE DIOS

NEW DOJ BUILDING, Q.C.
Quezon City

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