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    Sample Motion for Re-Raffle



    REPUBLIC OF THE PHILIPPINES
    NATIONAL CAPITAL JUDICIAL REGION
    MUNICIPAL TRIAL COURT IN CITIES
    CEBU CITY
    BRANCH 61


    PEOPLE OF THE PHILIPPINES,
    Complainant,

    vs.Crim. Case No. 123456
     For: RECKLESS IMPRUDENCE
     RESULTING IN DAMAGE TO PROPERTY


    AKU SADO,
    Accused,
    X------------------------X


    MOTION FOR RE-RAFFLE




    PRIVATE COMPLAINANT Jose De Juan, through the undersigned counsel, respectfully states that:

    1.  Private complainant was informed that this case will no longer be heard by Hon. Presiding Judge Mario De Pedro but by the Hon. Pairing Judge Ana Dela Cruz of Branch 63.

    2.  However, this case was originally raffled to Branch 63 presided by Hon. Dela Cruz and was re-raffled to this branch after the Judicial Dispute Resolution failed

    3.   Considering that Hon. Dela Cruz had previously heard private complainant's side during the JDR, the Consolidated and Revised Guideline on JDR disqualifies her from further trying this case. 

    4.  Consequently, private complainant respectfully submits that this case ought to be immediately referred to the Office of the Clerk of Court for re-raffling to another branch of this court.

    WHEREFORE, it is respectfully prayed that this case immediately be referred to the Office of the Clerk of Court for re-raffling. 

    Other just and equitable remedies are likewise prayed for.

                   (place)                ,          (date)       .



    ATTY. APRIL AGOSTO
    Counsel for the Accused
    19 Gorordo Ave., Lahug, Cebu City 
    Roll No. 666777
    IBP No. 222222/ 1-03-2016/Cebu City
    PTR No. 111111/ 1-03-2016/Cebu City
    MCLE Compliance No. IV-555566


    With my conformity:


    PROSECUTOR MARIEL ROVERA
    Office of the City Prosecutor, Cebu City


    NOTICE OF HEARING


    THE BRANCH CLERK OF COURT
    Municipal Trial Court in Cities, Branch 61
    Cebu City

    PROSECUTOR MARIEL ROVERA
    Office of the City Prosecutor, Cebu City
           
    ATTY. RAUL DE PEDRO
    Private Prosecutor
    1234 Lopez Jaena Street, Cebu City


    Please be notified that the undersigned will submit the foregoing motion for the consideration and approval of the Court on _________________ at ______________.



    ATTY. APRIL AGOSTO
    Counsel for the Accused



    Copy furnished by personal service:

    PROSECUTOR MARIEL ROVERA
    Office of the City Prosecutor, Cebu City
         
    ATTY. RAUL DE PEDRO
    Private Prosecutor
    1234 Lopez Jaena Street, Cebu City


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