MOTION FOR THE RELEASE OF SEIZED PASSPORT

COMES NOW, the movant-owner__________________, by

the undersigned Counsel and unto this Honorable (Office/Court) most
respectfully aver that:

1. Herein movant, _________________, is a Philippine

passport holder, bearing the following details:

Passport No.
Name:
Address:
Date of Issue:
Place of Issue:

2. After the time of the incident, the above-described passport

was seized by _________________, address, was
possessed at their office for reason that
____________________________;

3. Thus, considering that the subject item is not an element of

the crime charged, herein passport owner is begging the
Honorable Court to issue an order releasing the seized
passport to him, so that he can
 MOTION TO RELEASE PASSPORT

(Defendant), Juan dela Cruz, through counsel, submits the

following Motion to Release Passport and unto this Honorable Court
most respectfully aver that:

1. Juan dela Cruz is a Philippine passport holder, bearing the

following details:

Passport No.
Name:
Address:
Date of Issue:
Place of Issue:

2. Sometime on January 1, 2018, defendant surrendered his

passport pursuant to the Order of the Honorable Judge
________________ by reason of __________________.

3. Juan dela Cruz was released from his sentence and can no longer
be deemed considered as a serious flight risk.

Wherefore, premises considered, it is most respectfully prayed of

this Honorable Court to grant the foregoing motion and accordingly
issue an order releasing the passport of Juan dela Cruz.

Other relief just and equitable are likewise prayed for.

Respectfully submitted. October 19, 2018. Mandaue City,

Philippines.