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    Motion To Travel Sample

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    furry_attorney
    This document is a motion filed in a criminal case requesting permission for the accused, John Doe, to travel abroad. It summarizes that a hold departure order was previously issued against the accused but the parties later reached a compromise agreement. It further explains that the accused has been diagnosed with stage 3B colon cancer and needs to travel to New York for 15 days from March 1-15, 2010 for urgent medical treatment, as evidenced by attached medical and travel documents. It asserts that the accused has complied with the agreement and is not a flight risk, only traveling for needed medical care before returning on March 15. A hearing is scheduled on the motion for February 19.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Motion To Travel Sample

    Uploaded by

    furry_attorney
    6K views3 pages
    This document is a motion filed in a criminal case requesting permission for the accused, John Doe, to travel abroad. It summarizes that a hold departure order was previously issued against the accused but the parties later reached a compromise agreement. It further explains that the accused has been diagnosed with stage 3B colon cancer and needs to travel to New York for 15 days from March 1-15, 2010 for urgent medical treatment, as evidenced by attached medical and travel documents. It asserts that the accused has complied with the agreement and is not a flight risk, only traveling for needed medical care before returning on March 15. A hearing is scheduled on the motion for February 19.

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    Sample Motion to Travel Abroad (criminal case)

    Original Title

    Motion to Travel Sample

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    This document is a motion filed in a criminal case requesting permission for the accused, John Doe, to travel abroad. It summarizes that a hold departure order was previously issued against the accused but the parties later reached a compromise agreement. It further explains that the accused has been diagnosed with stage 3B colon cancer and needs to travel to New York for 15 days from March 1-15, 2010 for urgent medical treatment, as evidenced by attached medical and travel documents. It asserts that the accused has complied with the agreement and is not a flight risk, only traveling for needed medical care before returning on March 15. A hearing is scheduled on the motion for February 19.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    6K views3 pages

    Motion To Travel Sample

    Uploaded by

    furry_attorney
    This document is a motion filed in a criminal case requesting permission for the accused, John Doe, to travel abroad. It summarizes that a hold departure order was previously issued against the accused but the parties later reached a compromise agreement. It further explains that the accused has been diagnosed with stage 3B colon cancer and needs to travel to New York for 15 days from March 1-15, 2010 for urgent medical treatment, as evidenced by attached medical and travel documents. It asserts that the accused has complied with the agreement and is not a flight risk, only traveling for needed medical care before returning on March 15. A hearing is scheduled on the motion for February 19.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    REPUBLIC OF THE PHILIPPINES

    NATIONAL CAPITAL JUDICIAL REGION


    REGIONAL TRIAL COURT
    QUEZON CITY
    BRANCH 1
    PEOPLE OF THE PHILIPPINES
    CRIM. CASE NO.
    08-203040
    -versusJOHN DOE
    Accused.
    x----------------------------------------------------x

    MOTION FOR LEAVE TO TRAVEL


    ABROAD
    COMES NOW the undersigned counsel for the accused
    in the above-entitled case, respectfully moves this Honorable
    Court for permission to travel abroad for business purposes
    and in support thereof states:
    1. That in an Order dated February 3, 2009 this
    Honorable Court granted the private complainants Motion
    for Issuance of Hold Departure Order against the accused;
    2. That on November 5, 2009, the accused and the
    private complainant entered into a Compromise Agreement,
    which was approved by the Honorable Court on November
    19, 2009;
    3. That the accused has been diagnosed with Stage 3B
    colon cancer;
    4. That the accused to seek medical treatment in New
    York, U.S.A.;
    5. That in view of the above urgent health concerns,
    the accused is necessitated to travel abroad for a period of
    FIFTEEN (15) DAYS only from March 1-15, 2010;
    6.
    That the accuseds medical certificate, flight
    schedules and hotel accommodations are detailed in the
    itinerary prepared by the travel agency, hereto attached as
    Annexes 1 , 2, 3, and 4 respectively;

    7. That the accused has been fully compliant with his


    obligations under the said Compromise Agreement, and he is
    bent on complying faithfully with all the conditions specified
    therein;
    8. That the accused is not a flight risk. The above
    requested travel is necessary for his immediate medical
    treatment, and he will return to the country as scheduled on
    March 15, 2010.

    P R AY E R
    WHEREFORE, premises considered, it is respectfully
    prayed on this Honorable Court to grant this motion to allow
    the accused to travel abroad solely for business purposes.
    Other just and equitable reliefs are likewise prayed for.
    RESPECTFULLY SUBMITTED.
    Quezon City, February 10, 2010.

    MEEZ CONGENIALY TY
    Counsel for the Accused
    PTR No.112345; Pasig City; 3 January
    2010
    IBP No. 23456; Pasig City; 5 January
    2010
    Attorney Roll No. 34567
    MCLE Compliance III No. 0001111
    123 Ditona Street
    Pasig City
    Telefax: (02) 666-6660
    e-mail: [email protected]

    NOTICE OF HEARING
    THE CLERK OF COURT
    Regional Trial Court
    Branch 1, Quezon City
    Assistant City Prosecutor AL CAPON
    Office of the City Prosecutor
    Quezon City Hall
    Atty. Gringo Poe
    Counsel for the Private Complainant

    Rm 55, The Round Table


    Quezon City

    G R E E T I N G S:
    Please take notice that the undersigned shall submit
    the foregoing motion for the kind consideration and approval
    of this Honorable Court on February 19, 2010 at 8:30 in the
    morning as counsel shall be heard.

    MEEZ CONGENIALY TY

    Copy Furnished:
    Assistant City Prosecutor AL CAPON
    Office of the City Prosecutor
    Quezon City Hall
    Atty. Gringo Poe
    Counsel for the Private Complainant
    Rm 55, The Round Table
    Quezon City

    Explanation
    The undersigned counsel informs the Honorable Court
    that copy of the foregoing motion was served upon the
    above-named counsel by registered mail due to distance and
    time constraints, and unavailability of messenger to effect
    personal service.
    MEEZ CONGENIALY TY

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