Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 25
Davao City

PEOPLE OF THE PHILIPPINES

Criminal Case No. 3442
For: SWINDLING
- versus– Under Article 315,
Paragraph 2(a)
ARNEL STONEFIST, Of the Revised
Indian National, Penal Code
Accused,
x------------------------------------------x
URGENT EX-PARTE MOTION FOR THE ISSUANCE OF HOLD DEPARTURE
ORDER OF
ARNEL STONEFIST

COMES NOW, the Private Complainant, by the undersigned public

prosecutor and unto this Honorable Court, respectfully moves for the
issuance of the Hold Departure Order (HDO) and warrant of arrest against
the accused, and alleges that:

1) The Accused is ARNEL STONEFIST as indicated in the photocopy of his

passport;

2) The Accused is an Swedish National and is a businessman by profession

and notoriously known as the owner of SWEDY CHEESE BALLS;

3) That ARNEL STONEFIST jumped bail in another case in RTC Branch 21

with Docket No. 231 ;

4) A copy of ARNEL STONEFIST’s passport indicating his correct name and

nationality is herewith attached as Annex “A”.

5) Due to the access of the Accused to flights, the Private Complainant is

left with no other remedy but to pray of this Honourable Court to issue the
Hold Departure Order against the accused ARNEL STONEFIST.

PRAYER
 WHEREFORE, it is respectfully prayed of this Honorable Court that
ARNEL STONEFIST, an Indian National, be held under a HOLD DEPARTURE
ORDER and it is mostly further prayed that other just and equitable
remedies be granted in favor of Private Complainant.

RESPECTFULLY SUBMITTED.

DONE. Davao City, Philippines. March 18, 2020.

VILLARIN LAW
Unit 11 & 12,City Triangle Corporate Center,
CM Recto St., Davao City

By:

ATTY. PAULO JOSE S. VILLARIN

Counsel of the Complainant
Roll of Attorneys No. 696969
PTR No. 69669, 4-24-20, Davao City
IBP No. 5559, 4-24-20, Davao City
MCLE Compliance No. VII-0220293; 4-19-19
Valid until April 14, 2022
Ecoland, Davao City