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DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE-REGION III
OFFICE OF THE CITY PROSECUTOR
CITY OF SAN JOSE DEL MONTE, BULACAN
MOTION TO RELEASE
Comes Now, the movant ARNULFO O. MORENO JR., unto this Honorable
Office, most respectfully state that:
Movant is the absolute and lawful owner and in possession of Volvo S40 car
with Plate No. WDW 882 and Professional Driver’s Licence No. N25-11-010190;
That the above vehicle and driver’s licence card are currently impounded at
the Police Station of the City of San Jose Del Monte, Bulacan, by virtue of the filing
of the aforesaid case;
On January 11, 2018, around 9:00 o’clock in the morning, the movant was
involved in a vehicular accident, while driving the above vehicle, at Cedar St., Grand
Cypress, Brgy. Tungkong Mangga, City of San Jose Del Monte, Bulacan, wherein he
accidentally bumped, Prince Rovin S. Sapra, 3 years old, who suddenly crossed the
street despite the presence of his mother. The movant, with the boy’s mother,
brought the young child to Brigino Hospital but the latter succumbed to death while
undergoing treatment;
It is respectfully prayed that the above personal property, i.e. vehicle and
driver’s license card, be released to the movant so he can safe keep and use the
same;
The movant promises that should the Honorable Office of the City Prosecutor
or the Court find it necessary to produce the same during the course of the
proceedings and or trial, movant undertakes to produce the same.
PRAYER
Other relief just and equitable under the premises are likewise prayed for.
AFFIDAVIT OF UNDERTAKING
END OF AFFIDAVIT.
SUBSCRIBED AND SWORN TO before me this ____ day of January 2018, at San
Jose Del Monte City, Bulacan. Affiant exhibiting to me his GSIS ID No.
006-0036-2164-6 as his means of identification.