Republic of the Philippines

SANDIGANBAYAN
Quezon City
SECOND DIVISION

PEOPLE OF THE PHILIPPINES,

-versus- CRIM. CASE NO. SB-16-CRM-2091

For: Violation of Sec. 3 (e) RA 3019

EMILIANO KHO y SANDOVAL et al.,

Accused.

x-------------------------------------------x

MOTION FOR PRODUCTION AND INSPECTION OF DOCUMENTS

Comes now accused EMILIANO S. KHO, by counsel, respectfully

moving for an order requiring plaintiff PEOPLE OF THE PHILIPPINES:

1. To produce and permit defendant to inspect and to copy each of

the following documents:

 Letter-Complaint dated June 20, 2016 of private

complainants Anita O. Paz and Romulo C. Ozaeta
 Supplementary Letter-Complaint dated July 4, 2016 of
private complainant Romulo C. Ozaeta
 Handwritten “Kasunduan” dated August 21, 2015 allegedly
executed between accused Emiliano S. Kho and Dorcas
Mining Corporation
 Chinabank Congressional Branch Check No. 189452 dated
November 2, 2015 in the amount of Php 250,000.00
 Chinabank Congressional Branch Check No. 190834 dated
December 3, 2015 in the amount of Php 750,839.22

2. Plaintiff has the possession, custody or control of each of the

foregoing documents and objects. Each of them constitutes or contains
evidence relevant and material to the matter involved in this criminal
case.
3. Said copies of the above-mentioned documents are urgently
needed in order to prevent unnecessary alteration and suppression of
records on the part of the prosecution and to justifiably allow the defense
to sufficiently prepare its counter-allegations against said complainant.
EMILIANO KHO y SANDOVAL et al.,
Crim. Case No. SB-16-CRM-2091

Page 2 of 3

4. This motion is made pursuant to Section 10 of Rule 116 of the

1997 Revised Rules of Criminal Procedure.

Respectfully given this 13th day of January 2017, Quezon City,

Philippines.

ATTY. JAMES EARL REYES

Counsel for Accused
Roll No. 32789
IBP. Receipt No. 379423/2-7-2016
MCLE Compliance No. V-31400

REQUEST FOR HEARING

THE DIVISION CLERK OF COURT

SANDIGANBAYAN
Second Division
Quezon City

Greetings!

Please submit the foregoing Motion to the Court for its

consideration and approval immediately upon receipt hereof and kindly
include the same in the court’s calendar for hearing on Friday, 27
February 2017 at 8:30 in the morning.

ATTY. JAMES EARL REYES

Counsel for Accused
Roll No. 32789
IBP. Receipt No. 379423/2-7-2016
MCLE Compliance No. V-31400

Copy furnished:

Deputy Special Prosecutor Atty. Natividad E. Santos

OFFICE OF THE SPECIAL PROSECUTOR
4th Floor Ombudsman Building
Agham Road, Quezon City
EMILIANO KHO y SANDOVAL et al.,
Crim. Case No. SB-16-CRM-2091

Page 3 of 3

Copies of the foregoing Motion for Production and Inspection

of Documents have been served through registered mail due to lack of
personnel for personal service. Please take notice that counsel has
requested to be heard on 27 February 2017 at 8:30 in the morning.

ATTY. JAMES EARL REYES

Counsel for Accused
Roll No. 32789
IBP. Receipt No. 379423/2-7-2016
MCLE Compliance No. V-31400