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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


__________________
__________________

THE PEOPLE OF THE PHILIPPINES,


Plaintiff,

- versus - CRIM. CASE NOS. _________

______________________________________
Accused.
X-------------------------------X

MOTION

COMES NOW, the accused _______________, thru movant,


________________ of ___________________, sister of the accused, and
unto this Honorable Court respectfully alleges:
1. That the accused is presently detained at the Provincial Jail,
_______________;

2. That the grandfather of the accused, ______________ died on


______________________ attached hereto is the death
certificate of the grandfather of the accused marked as
Annex A and the interment of said deceased is on
________________________;

3. That the accused wants to pay a visit to the wake of his


grandfather for the last time before he is buried;

WHEREFORE, premises considered, it is respectfully prayed


before this Honorable Court that the accused be allowed to visit the
wake of his deceased grandfather, _______________ at ______________
on ___________________.
_________________________.

______________________________________

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