Republic of the Philippines
REGIONAL TRIAL COURT
11th Judicial Region
Davao City
Branch 12
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case No. 123456
- versus - For: RAPE
KANYE WEST,
Accused.
x ------------------------------------------ x
MOTION TO REDUCE BAIL
Accused, through counsel, by way of a special appearance solely for this
purpose, respectfully alleges:
1.That the accused has been charged with RAPE and that the bail for his
provisional release has been set at Php 200,000.00;
2. That the accused is a poor fellow of very limited means such that it is
impossible for him to pay the full amount of his bond and is therefore
constrained to request for a reduction of the amount of bail;
3. That it would be advantageous to everyone if he be given temporary
liberty thereby allowing him to continue with his gainful employment and as
head of the family with four (4) dependents;
4. As such, accused appeals to the mercy and compassion of this Honorable
Court and respectfully requests that his bail be reduced to P 70,000.00.
5.That this motion for reduction of bail is being filed without prejudice to
any other remedy which may be available to the accused and that the
accused expressly reserves the right to question the legality of the issuance
of the search warrant or his warrantless arrest if the circumstances would so
warrant.
WHEREFORE, accused respectfully prays that his bail be reduced to P
70,000.00.
Other relief just and equitable are likewise prayed for.
Davao City, Philippines. February 20, 2020.
SGD.
Atty. Jules Andre B. Vosotros
Counsel for Accused
Roll of Atty. No 2016400051
IBP No. 24123;
PTR No. 2002212E; 12/18/2020; Davao City
5F/Landco Bldg.
Bajada St., Davao City, Philippines
(082) 220-2665 | 09773415206
AttyJAV@gmail.com
NOTICE OF HEARING
Branch Clerk of Court
RTC Br. 12
Davao City, Philippines
Office of the City Prosecutor
Hall of Justice
Davao City, Philippines
Greetings!
For the convenience and for the economy of time and expense of all
concerned, and with the kind indulgence of the Court, we shall present this
Record on Appeal to the Court on April 20, 2020. A previous setting which
has been earlier scheduled by the Court for the preliminary conference of the
instant case. Thank you.
SGD.
Atty. Jules Andre B. Vosotros
Counsel for Accused
Roll of Atty. No 2016400051
IBP No. 24123;
PTR No. 2002212E; 12/18/2020; Davao City
5F/Landco Bldg.
Bajada St., Davao City, Philippines
(082) 220-2665 | 09773415206
AttyJAV@gmail.com
Copy Furnished:
Office of the City Prosecutor.
Hall of Justice
Davao City, Philippines
(Personal Delivery)
Presiding Judge
Regional Trial Court
Branch 12
Hall of Justice
Davao City, Philippines
(Personal delivery)
EXPLANATION
A copy hereof is served on the Office of the Ombudsman via
registered mail due to the distance of the office address of said Office, due to
the lack of field staff of undersigned counsel at this time, and due to the
urgency of filing the same.
SGD.
Atty. Jules Andre B. Vosotros
Counsel for Accused
Roll of Atty. No 2016400051
IBP No. 24123;
PTR No. 2002212E; 12/18/2020; Davao City
5F/Landco Bldg.
Bajada St., Davao City, Philippines
(082) 220-2665 | 09773415206
AttyJAV@gmail.com
