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Accused, through Counsel, and unto this Honorable Court most respectfully
moves for the RELEASE of one (1) HAIMA HATCHBACK SEDAN (White) with
Conduction Sticker SM-1667. Thus, MOVANT avers the following in support of
this Motion, THAT:
3. On February 28, 2017, Accused was able to post bail for the offense being
charged against him in the following amount: Thirty Thousand Pesos
(Php30,000.00) covered by Official Receipt No. 6665958C for NPS No. III-
13-INQ-18-B-00125;
4. However, despite such cash bond having been posted, approved and
accepted with the Accused being able to enjoy his provisional liberty, the
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above-described vehicle remains in the custody of the Community Police
Assistance Center-3, Sindalan, City of San Fernando, Pampanga;
5. With all humility, Accused pleads that the subject motor vehicle be released
as he is using the same in going to and from work. However, upon the release
thereof, Respondent undertakes, by virtue of an “Affidavit of Undertaking”,
hereto attached as Annex “2”, that the above-mentioned vehicle shall be
brought to this Honorable Court if needed and required;
7. Considering that there is no more reason to retain custody over the said
vehicle as there had been a proper documentation and inventory, its release
should be ordered immediately;
PRAYER
Other reliefs just and equitable under the premises are likewise prayed for.
RESPECTFULLY SUBMITTED.
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By:
JEROME I. FLORES
Police Officer 3 – Investigator
Community Police Assistance Center – 3
City of San Fernando Police Station
Pampanga, Philippines
EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)
Copies of this MOTION TO RELEASE IMPOUNDED VEHICLE have been sent to the
above-named office/person(s) through registered mail due to lack of office
personnel, as well as due to distance and time constraints to effect personal service.