motion to postpone arraignment

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REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION CITY OF PARAÑAQUE BRANCH 258 PEOPLE OF THE PHILIPPINES, - versus - MARCELINO M. LAZARO, JR., Accused. CRIM. CASE No. 14- 0431 For: Violation of Section 74, In Relation to Section 144 of the Corporation Code x---------------------------------------x MOTION TO POSTPONE ARRAIGNMENT Accused, through counsel, to this Honorable Court, most respectfully states that: 1. On August 20, 2015, undersigned counsel submitted its Motion for Reconsideration of this Honorable Court's Order dated July 24, 2015. 2. On August 24, 2015, this Honorable Court issued an ORDER, giving the Public and Private Prosecutor ten (10) days from receipt of the said Order within which to file their respective Comment. 3. Since the Motion for Reconsideration filed before this Honorable Court was for the suspension of the criminal proceeding, by reason of the Motion to Postpone Arraignment Page 1 of 4

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Page 1: Motion to Postpone Arraignment

REPUBLIC OF THE PHILIPPINESREGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGIONCITY OF PARAÑAQUE

BRANCH 258

PEOPLE OF THE PHILIPPINES,

- versus -

MARCELINO M. LAZARO, JR.,

Accused.

CRIM. CASE No. 14-0431For: Violation of Section 74, In Relation to Section 144 of the Corporation Code

x---------------------------------------x

MOTION TO POSTPONE ARRAIGNMENT

Accused, through counsel, to this Honorable Court, most respectfully states that:

1. On August 20, 2015, undersigned counsel submitted its Motion for Reconsideration of this Honorable Court's Order dated July 24, 2015.

2. On August 24, 2015, this Honorable Court issued an ORDER, giving the Public and Private Prosecutor ten (10) days from receipt of the said Order within which to file their respective Comment.

3. Since the Motion for Reconsideration filed before this Honorable Court was for the suspension of the criminal proceeding, by reason of the existence of a prejudicial question, undersigned counsel prays that the arraignment of the Accused, scheduled on August 27, 2015, be suspended pending the resolution of the Motion for Reconsideration submitted.

4. This motion is not intended to delay the proceedings but is being filed by reason of the foregoing facts and for the conduct of orderly and fair proceedings.

Motion to Postpone ArraignmentPage 1 of 3

Page 2: Motion to Postpone Arraignment

PRAYER

WHEREFORE, it is respectfully prayed that this Honorable Court SUSPEND the arraignement scheduled on August 27, 2015, pending the resolution of this Honorable Court for the Motion for Reconsideration filed by the Accused.

Respectfully submitted.

August 24, 2015, Makati City for the City of Parañaque.

Counsel for the Accused:

roscorROY LAW OFFICES

CORPORATE CONSULTING & LITIGATIONSuites 607-608 Cattleya Condominium

235 Salcedo Street, Legaspi Village, Makati CityT: +63.2.817.1095•63.2.817.1096

JOSE M. ROY IIIIBP LRN 02570/August 20, 2001 (Lifetime)PTR No. 0038311/Jan. 5, 2015/Makati City

Roll of Attorneys No. 37065MCLE Exemption No. I-000176

PONCIANO DEXTER HECTOR S.CORPUSIBP No. 09888 (Lifetime)

PTR No. 0045931/Jan. 5, 2015/Makati CityRoll of Attorneys No. 59289

MCLE COMP. IV-13994-3/March 27, 2013

Motion to Postpone ArraignmentPage 2 of 3

Page 3: Motion to Postpone Arraignment

NOTICE/COPIES FURNISHED

THE BRANCH CLERK OF COURTRegional Trial CourtroomBranch 258, Parañaque City

PUBLIC PROSECUTOROffice of the City ProsecutorParañaque City

PARAS AND MANLAPAZ LAW OFFICESCounsel for the Complainant1402 Equitable Bank Tower,8751 Paseo De Roxas, Makati City

GREETINGS:

Kindly submit the foregoing Motion to Postpone Arraignment for the consideration of and approval by this Honorable Court immediately upon receipt hereof, without further arguments.

EXPLANATION

Copies of the foregoing Motion was served by personal delivery.

PONCIANO DEXTER HECTOR S. CORPUS

Motion to Postpone ArraignmentPage 3 of 3