Republic of the Philippines

REGIONAL TRIAL COURT OF MISAMIS ORIENTAL

10th Judicial Region
Branch 23
Cagayan de Oro City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2009-880

Plaintiff,

FOR: ESTAFA
--versus—

RODERICK ROXAS Y CARZON,

Accused.
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EXPLANATION WITH MOTION TO WITHDRAW

COMES NOW, the undersigned counsel, and unto this Honorable Court,
most respectfully states that:

1. The undersigned received a copy of the 16 June 2011 Order of this

Honorable Court asking him to explain his absence as counsel for the
accused in the June 16, 2011 of the criminal case People vs. Roderick
Roxas for Estafa, docketed as Crim. Case No. 2009-880.

2. Sometime on February 2011, the undersigned counsel was requested by

the accused’ wife to assist them in obtaining a reduced bailbond from
this Honorable Court as their lawyer, Atty. Teofredo Rojas was
unavailable during that time. Assenting to their request, the undersigned
filed an Urgent Motion to Reduce Bailbond sometime on March 3, 2011.

3. Subsequently thereto, the undersigned counsel was informed by

accused Roderick Roxas and his wife, that Atty. Teofredo Rojas was to
represent the accused from hereon end as well as in the succeeding
court hearings.

4. The undersigned never intended to delay the proceedings of this

Honorable Court, and his absence on June 16, 2011 was precisely
 because the accused has entrusted his defenses in the person of Atty.
Teofredo Rojas. and so accordingly, the undersigned counsel could never
appear in any of the court proceedings upon the express direction of the
accused and his wife.

5. In view thereof, and in order to avoid an overlapping of responsibilities

between Atty. Ken Sur and Atty. Teofredo Rojas, the undersigned
respectfully requests that his name be stricken off or withdrawn as
counsel for the accused, Roderick Roxas.

WHEREFORE, premises considered, it is respectfully requested that the

Honorable Court accept the aforementioned explanation and subsequently grant
the respective motion to withdraw as counsel for accused Roderick Roxas Y
Carzon.

Cagayan de Oro City, June 23, 2011.

_________ ________
KEN RINEHART V. SUR
Movant
NOTIFICATION

Office of the City Prosecutor

Cagayan de Oro City

Hon. Clerk of Court

Branch 23
Regional Trial Court
Cagayan de Oro City

Greetings:

Please be informed that the instant motion, being non-litigous in nature, is

submitted for the consideration and resolution of the Honorable Court immediately
upon receipt hereof.

KEN RINEHART V. SUR