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Motion for Travel Approval in Cyberlibel Case

Felma Dalagan has filed a motion requesting permission from the court to accompany her two children to Japan for their study from October 22 to October 31, 2023. Dalagan is currently facing cyberlibel charges and her arraignment is scheduled for November 17, 2023. However, there are no other immediate family members who can send the children to Japan for their studies. Dalagan is asking the court to allow her to travel abroad with her children during this period and return before her court hearing.

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kent rickx pede
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86 views2 pages

Motion for Travel Approval in Cyberlibel Case

Felma Dalagan has filed a motion requesting permission from the court to accompany her two children to Japan for their study from October 22 to October 31, 2023. Dalagan is currently facing cyberlibel charges and her arraignment is scheduled for November 17, 2023. However, there are no other immediate family members who can send the children to Japan for their studies. Dalagan is asking the court to allow her to travel abroad with her children during this period and return before her court hearing.

Uploaded by

kent rickx pede
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

REGIONAL TRIAL COURT


10th Judicial Region
Branch 14
Oroquieta City

PEOPLE OF THE PHILIPPINES


Plaintiff,
Vs. FOR: CYBERLIBEL

GLEEN B. DALAGAN and FELMA B. DALAGAN.


Respondent
X------------------------------------------------------/

MOTION TO ALLOW THE ACCUSED TO ACCOMPANY HER CHILDREN


IN GOING ABROAD

Accused, FELMA B. DALAGAN, through the undersigned counsel


and unto this Honorable Court, respectfully states that:

1. On November 17, 2023 accused Felma Dalagan is set for


Arraignment and Pre-trial of this instant case;

2. However, prior to the aforementioned date, the accused will go to


Japan to send her two(2) children namely, Kian Dalagan and
Yohan Dalagan for their study in Japan;

3. The date of their departure here in the Philippines is on October


22, 2023 and the accused is set to arrive back in the Philippines
on October 31, 2023, proof of which is the plane ticket booked by
the accused which is hereto attached and marked as
Annex_______________;

4. There was no immediate members of the family who can


accompany the children of the accused other the accused herself;

5. This motion is filed in good faith and is not intended to delay the
proceedings;

6. As such, the accused begs this Honorable Court to allow the


accused to accompany her children in going to Japan for her
children's study;

PRAYER
WHEREFORE, this Honorable Court is prayed to allow the
accused to accompany her children in going abroad for the study of her
Page PAGE \* MERGEFORMAT 2
abovenamed children from October 22, 2023 and to come back in the
Philippines on October 31, 2023.
Other just reliefs are likewise prayed for.

October 6, 2023, Oroquieta City.

RESPECTFULLY SUBMITTED.

PEDE LAW OFFICE


Counsel for Accused
Purok 4, Independence St.
Poblacion II, Oroquieta City
0907-239-5339/0966-473-4594
Email: pedelawoffice@[Link]

By: KENT RICKX S. PEDE


Roll. No. 72492
IBP O.R No. 195426; 01-04-2022
PTR No. 0186850; 01-04-2022
MCLE Compliance No. VII- 0019210
Valid until April 14, 2025

PROOF OF SERVICE

Copy Furnished:

OFFICE OF THE PROVINCIAL PROSECUTOR


Poblacion II, Oroquieta City

KENT RICKX S.
PEDE

Page PAGE \* MERGEFORMAT 2

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