Affiant personally came and appeared with Driver’s License ID No. SUBSCRIBED AND SWORN TO BEFORE ME, A Notary public in and for the City of Puerto Princesa and the Province of Palawan this 24 th day of October 2013. IN WITNESS WHEREOF, I have signed this affidavit this 24 th day of October 2013 at Puerto Princesa City. Goy, counsel for the Plaintiff, by personal service by delivering personally copy of said Motion upon said lawyer who acknowledged receipt there of as shown by his signature or initial on the said pleading, this 23 rd day of October 2013 65448, and that such messenger I served upon the counsel of adverse party and other parties, the Motion for Consideration filed in said case, as follows:Ītty. Venturillo, Counsel for the defendant in the case entitled Alexander Bermejo vs. 1980), and defendants cannot use a bill of particulars to obtain the governments witness list. I, _, of legal age and having been duly sworn depose and say: Bills of particular should be granted sparingly 'to avoid freezing the Governments evidence in advance of trial,' United States v. Please be informed that the undersigned counsel has set the foregoing Motion for Reconsideration for hearing on Novemat 8:30 am, for the consideration of the Honorable Court or soon thereafter as counsel maybe heard. WHEREFORE, defendant prays that plaintiff be ordered to file a bill of particulars of the facts and acts constituting the conclusions alleged in the complaint. The foregoing allegations are conclusions of law, which plaintiff should clarify and flesh them with facts and specific acts to enable defendant-movant to prepare and file a responsive answer thereto which requires information as to precise nature, character, scope and extent of plaintiff’s cause of action. The complaint alleges that defendant public official, together with herein defendant movant, acting singly or collectively, and or in unlawful concert with one another, in flagrante breach of public trust and of sheer fiduciary obligations as public officers with gross and scandalous abuse of right and power and in brazen violation of the Constitution and laws of the Philippines, embarked upon a systematic plan to accumulate ill-gotten wealth. Please contact us online or call our Cincinnati office directly at 51 to schedule your free consultation.Defendant, by counsel and to this Honorable Court, respectfully states: Adams is recognized by Super Lawyers, Best Lawyers, The Best Lawyers in America, National Trial Lawyers Top 100, and is one of U.S. If you are facing criminal charges, you need to speak with an experienced criminal defense attorney as soon as possible. Are you or someone you know facing criminal charges? If you know, and even have proof, that you could not have been where the government says you were, then you have a viable alibi defense that may serve as a complete defense to the drug charges against you. Then, you can begin putting together where you were on that date and time. Therefore, by requesting a bill of particulars, you and your attorney can know when the act happened. A motion for a bill of particulars may be made before arraignment or within 10 days after arraignment or at such later time as the court may permit. You and your attorney cannot begin to put an alibi together without knowing when the government is claiming you committed the drug offense. The court may direct the filing of a bill of particulars. A Bill of particulars allows for the defense to request specific details regarding the case in order to avoid. The “when” aspect of a bill of particulars is very important especially if you claim that you did not commit the offense. A Bill of Particulars also allows the defense to properly prepare his or her defense in terms of a possible alibi, witnesses, times and dates of the accused crime, and other details that aid in the argument of the defense.
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