Motion to Release Impounded Vehicle



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

PEOPLE OF THE PHILIPPINES,

vs.Crim. Case No. 123456
 For: RECKLESS IMPRUDENCE
 RESULTING IN SERIOUS PHY. INJURIES
AKU SADO,
Accused,
X----------------------------------------X


MOTION TO RELEASE IMPOUNDED VEHICLE 


COMES NOW, movant JUAN DELA CRUZ, by himself, unto this Honorable Court, respectfully states that:

1.  Movant with residential address at 1234 Colon Street, Cebu City, is the registered owner of  Isuzu dump truck with Plate No. KLD-456 as evidenced by Official Receipt and Certificate of Registration issued by the Land Transportation Office, copies of which are hereto attached as Annexes "A" and "A-1";

2.  The said vehicle was involved in a vehicular accident on August 3, 2019 at 4:00 in the afternoon in Barangay Kalubihan, Cebu City, causing physical injury to one Pedro Santos;

3.   That said vehicle was impounded and currently under the custody of Kalubihan Police Station;

4.   The said vehicle is being utilized by the movant in his business and was never intended to be used for any illegal purpose;

4.   The continued impouding of the said vehicle has impaired the movant's capacity to earn and would further cause the vehicle's deterioration;

5.   Movant will ensure the delivery of the above described motor vehicle to the Honorable Court when needed in the course of the proceedings;

6.   Movant shall endeavor to attend all succeeding hearings in the above-captioned case. If movant anticipates that he may not be able to appear for just and valid reasons, he shall immediately inform this Honorable Court;

7.   This motion is not intended to delay the proceedings of this case but solely for the reasons stated above.

WHEREFORE, it is respectfully prayed that an Order be issued for the release of the above described motor vehicle from the custody of the Cebu City Police Station Traffic Investigation Unit and deliver the same to movant.

Other just and equitable remedies are likewise prayed for.

               (place)                ,          (date)       .



JUAN DELA CRUZ
Movant


NOTICE OF HEARING


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

PROSECUTOR MARIEN ROVERA
Office of the City Prosecutor, Cebu City
       
ATTY. AB CD
Private Prosecutor
2233 Colon Street, Cebu City

ATTY. QR YZ
Counsel for the Accused
Wilson Street, Lahug, Cebu City


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

               (place)              ,          (date)       .


JUAN DELA CRUZ
Movant


Copy furnished by personal service:

PROSECUTOR MARIEN ROVERA
Office of the City Prosecutor, Cebu City

ATTY. AB CD
Private Prosecutor
2233 Colon Street, Cebu City

ATTY. QR YZ
Counsel for the Accused
Wilson Street, Lahug, Cebu City