URGENT EX PARTE MOTION
TO TRANSCRIBE THE MOBILE PHONE
OF THE RESPONDENT NOW IN THE POSSESSION
OF THE HEARING OFFICER OF THE xxx OF THE xxx
The RESPONDENT, assisted by counsel, respectfully states:
1. On June 6, 2017 at about 10:30 AM the respondent personally followed up with the Presiding Hearing Officer (Atty. xxx) of the xxx his pending motion to recover his mobile phone from the xxx City Police Station and/or the Anti Cybercrime Group and/or whoever was in possession hereof so that he could TRANSCRIBE the relevant texts messages stored therein to corroborate and confirm his defenses in relation to the instant administrative case.
2. The Hearing Officer allowed the respondent to transcribe the contents of his mobile phone provided the activity would be collectively done in the presence of the Hearing Officer, the Prosecutor, the Forensic Examiner of the Anti-Cybercrime Group, and the Respondent at the premises of the Anti-Cybercrime Group on such a date and at such time as may be determined by the Hearing Officer and with prior notice to all concerned.
3. The Hearing Officer informed the respondent to file with his office the necessary MOTION to formalize the foregoing matter. Hence this motion.
4. The respondent hereby expresses his gratitude for the kind permission granted by the Hearing Officer.
5. In the interest of truth and justice, and pursuant to the constitutional rights of the respondent to due process of law, equal protection of the law, and security of tenure, the foregoing TRANSCRIPTION is of absolute importance to the defenses of the respondent in the instant administrative case.
WHEREFORE, premises considered, it is respectfully prayed that the Hearing Officer soonest schedule the foregoing collective TRANSCRIPTION of the mobile phone of the respondent in the presence of the Hearing Officer, the Prosecutor, the Forensic Examiner of the Anti-Cybercrime Group, and the Respondent at the premises of the Anti-Cybercrime Group on such date and at such time to be determined by the Hearing Officer.
Further, the respondent respectfully prays for such and other reliefs as may be deemed just and equitable in the premises.
Xxx City, xxx 2017.