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Regional Trial Court

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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


___ JUDICIAL REGION
BRANCH ____
______ City

PEOPLE OF THE PHILIPPINES,


Crim. Case No.
-versus-

JUAN DELA CRUZ,


Accused.
x--------------------x

MOTION FOR LEAVE OF COURT to file


DEMURRER TO THE EVIDENCE

Comes Now, Accused, through counsel, respectfully states:

1. That the prosecution has presented its witnesses and has formally offered its evidence;

2. That the admissibility of exhibits so offered had been resolved in the order dated April 28,
2005 which was received by the undersigned counsel on May 3, 2005;

3. That the accused seeks leave of court to file a Demurrer to the Evidence. on the ground that
the evidence presented by the prosecution is not sufficient to warrant a conviction of the guilt
of the accused beyond reasonable doubt;

4. That this motion is filed in good faith and not for the purpose of delaying the proceedings of
this case;

WHEREFORE, it is respectfully prayed that the accused be granted Leave of Court to


file a Demurrer to the Evidence.

Davao City, Philippines, May __, 2005.

_______________
Counsel for the Accused

NOTICE OF HEARING

Pros. ________________
The City Prosecutor’s Office

Please be notified that the undersigned has set the hearing of this motion for leave of
court for the consideration of the Honorable Court on ___________ at 8:30 am without further
oral argument and sans appearance of counsel.

Thank you.

__________________________
Name and signature of Counsel

Copy furnished:

Pros. _________
Office of the City Prosecutor

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