REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11TH JUDICIAL REGION
Davao City, BRANCH 05

RONALD JOHN A. LAO,

Plaintiff,

Civil Case No.

- versus - For: COLLECTION
OF SUM OF
MONEY
LOURIE MAE CALLOPE,
Defendant.

x ----------------------------------- x
MOTION TO WITHDRAW INFORMATION

PLAINTIFF People of the Philippines, through the undersigned State

Prosecutor and to the Honorable Court, most respectfully states:

In a Resolution dated [DATE OF RESOLUTION], the City Prosecutor of

[PLACE], [NAME OF THE CITY PROSECUTOR], found probable cause
that the accused committed the crime of [CRIME] under [SECTION OF
THE LAW VIOLATED] and should be held for trial, to wit:

[Insert the Dispositive Portion of the Resolution]

Pursuant to the said Resolution dated [DATE OF RESOLUTION], the City

Prosecutor of [PLACE], [NAME OF THE CITY PROSECUTOR], filed on
[DATE OF FILING OF THE INFORMATION] the following Information
against the accused, which was thereafter raffled to this Honorable Court:

[Reproduce relevant portion of the Information]

[Insert reasons for moving for the withdrawal of the Information].

In view thereof, plaintiff respectfully moves for the withdrawal of the above-
quoted Information dated [DATE OF THE INFORMATION] against the
accused

This Motion to Withdraw Information is filed in good faith and is not

intended to delay the proceedings in the instant case, but is caused solely by
the reasons stated above.

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PRAYER

WHEREFORE, premises considered, plaintiff respectfully prays that the

Information dated [DATE OF THE INFORMATION] against the accused
be WITHDRAWN and that the case against the accused be DISMISSED.

Davao City, March 12, 2020.

Atty. Jonah Margarette F. Presto

Counsel for the Defendant
Presto and Aligato Law Firm
Avocado Building, JP Laurel, Davao City
prestojonahmargarette@gmail.com
Roll No. 64564 issue on 1/3/2017 at Davao City
IBP No. 067990 issued on 5/3/2017 at Davao City
PTR No. 098765 issued on 6/3/2017 at Davao City
MCLE Compliance XI-0013922

REQUEST FOR HEARING

THE BRANCH CLERK OF COURT

Municipal Trial Court
Branch 10, Davao City

Please submit the foregoing Motion to the Court for its consideration
and approval immediately upon receipt hereof and kindly include the same
in the court’s calendar for hearing on Friday, March 13, 2020 at 2:00 o’clock
in the afternoon.

NOTICE OF HEARING

Atty. Erika Aira De Peralta

Counsel for the Plaintiff
De Peralta Law Firm
Mango Building, Bajada, Davao City

Please take notice that counsel has requested to be heard for this
motion on Friday, March 13, 2020 at 2:00 o’clock in the afternoon.

Atty. Jonah Margarette F. Presto

Counsel for the Defendant
Presto and Aligato Law Firm
Avocado Building, JP Laurel, Davao City

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Copy furnished through personal service:

Atty. Erika Aira De Peralta

Counsel for the Plaintiff
De Peralta Law Firm
Mango Building, Bajada, Davao City