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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR
LAGUNA

COMMUTER CARRIER INNOVATION INC.


Represented herein by
DEMETRIO PAGKANLUNGAN JR.
Complainant

-versus- NPS NO. 18A-00024


For: QUALIFIED THEFT and
OTHER VIOLATIONS OF RPC

NOEL MARBELLA AND


EDGAR BENTIR
Respondents.
X- - - -- - - - - - - - - - - - -X

MOTION TO REOPEN AND LEAVE TO ADMIT


REPLY AFFIDAVIT

COMES NOW, the Complainant, in the above-entitled case,


by and through the Undersigned Counsel and unto this
Honorable office, most respectfully avers:

1. That the instant case was deemed submitted for resolution


on February 14, 2018.
2. That the counsel was unable to arrive on time due to
unexpected conflict of schedule in the availability of the
witness to be presented.
3. That there is a paramount need and necessity that the case
be Reopened and that the Reply Affidavit together with the
Annexes.
4. The same herewith be Admitted before the Honorable
Investigating Prosecutor so that the case records may truly
bear out the real complaint in the case and for an orderly
investigation and Resolution of the case.
5. That this motion is not intended to delay the proceedings
and early disposition of the case.
P R A Y E R

WHEREFORE, premises considered, it is most


respectfully prayed of the Honorable Investigating Prosecutor
of the case that:

a. This Motion be given its due weight and credence;

b. That the instant case be Re-opened;

c. The Reply together with the Annexes herewith be


admitted so that the case records may truly bear out the
real complainant in the case and for an orderly
investigation and resolution of the case.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

City of Makati for Sta. Rosa Laguna February , 2018.

APSSAT LAW OFFICE AND ASSOCIATES


6/F Ricogen Building, Aguirre Street,
San Lorenzo Village, Makati City
Tel. No. (02) 504-8465
Apssat.lawofc@yahoo.com

ATTY. MOSES ELEAZAR B. PUA


PTR. NO. 7263227; 1-10-2018; Marikina
IBP No. 025794; 1-10-2018; Rizal
Roll No. 62637
MCLE Compliance No. V-0017012

N O T I C E

ANGELINE ORENDAIN
Prosecutor III

Greetings.

Please take notice that Undersigned Counsel will submit the


foregoing Motion for the kind consideration and approval of the
Honorable Investigating Prosecutor, immediately upon receipt
hereof.

ATTY. MOSES ELEAZAR B. PUA

EXPLANATION

This is to certify as an Officer of the Court that a copy of


MOTION was served, not by personal service but by registered mail
as herein-below indicated by reason of time, distance, lack of
manpower and urgency.

ATTY. MOSES ELEAZAR B. PUA

Copy furnished: