REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT OF QUEZON CITY

BRANCH 12PEOPLE OF THE PHILIPPINES,

Complainant,

-versus-

Criminal Case No.

Accused.

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

MOTION TO DEFER ARRAIGNMENT

Come now the accused in the above entitled cases, by undersigned counsel, most respectfully move for the deferment of their arraignment tentatively set on February 8, 2016, at 1: 30 pm, on the foregoing grounds.1. On December 18, 2015, herein accused received copy of the resolution of the Prosecutors Office of Quezon City recommending the filing of above cases based on corresponding informations prepared and subsequently filed by the Prosecutors Office.

2. Herein accused then filed a motion for extention of time for filing of a Petition for Review with the Department of Justice and on January 11, 2016, did file such a Petition for Review, copy of which is hereto attached.3. In order not to preempt the ruling that maybe rendered by the Department of Justice on the Petition for Review, it is most respectfully requested of the Honorable Court to defer aforementioned arraignment for a least 60 days by which time hopefully the Department of Justice may have made a ruling on such a Petition.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that the arraignment of the accused be reset for a period of at least sixty (60) days, or no earlier than 8 April 2016. Other reliefs just and equitable under the circumstances. Counsel for the AccusedCubao, Quezon City, Metro ManilaMCLE EXEMPTION NO.

NOTICE OF HEARING

The Clerk of Court

Metropolitan Trial Court

Branch, Quezon City

Office of the Quezon City ProsecutorGREETINGS:Please take note that the foregoing motion is being submitted for consideration of this Honorable Court on Friday, 35 January 2016, at 1:30 p.m. Copy furnished:

Office of the City Prosecutor

4/F Quezon City Hall of Justice

Quezon City Hall Compound

Quezon City