Republic of the Philippines

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QLD Floor, Ombudsman Building, Agham Road
Diliman, Quezon City (1104), Philippines

NA.REYNAFE DI. CAST[LLO. ET AL

O f B P A - 10 0273 - B

-versus
-

For:

viorAT]ONOF R .A .
6715
MISCONDUCT&GROSS
NEL]GENCE

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Respondents.

MOTONFORLEAVE

(TO THECOMPL)UN

FAEAND

LIITREPLY

JOINTPOsITIONP

ER)

Pubhc Respondent BAJOR GENERAL (IRGEN) ALFREDO sERINA

CARTO24, JR. APP {Ret), through the undersigned counsel, respectfully
prays for leave of this Honorable Office to be allowed to ltte a formal reply, a
copy of which is heTetO attached and marked as ANNEX A" and made as an
integral part hereof to the Joint Position Paper dated 0 1 October 20 10 filed
by fouT (4) of the Complainants who verified the pleading, based on the
following considerations, to wit:

1.

With the subI111SS1OI1 OH TeCOVd of the Joint Position Paper of the

Complainants in the abovedocketed administTative cases, there seems to be

MOTION FOR LEAVE TO ADMIT

OMB-P-A-10-027 -B
Page 2 of :5

X---------------------X

2.

The

balanced presentation of the facts

and

circumstances

attendant to the questioned act/ s or omission/ s constituting the alleged

grounds foT disciplinary action against the public respondents is/are
necessary in order that the Honorable Office

will

appreciate

the

respective

contentions of both parties all IOT the principal objective of serving the interest
of justice.

3. The introduction into the records of the proposed fOTITla 1 reply

by this Public Respondent after submitting his Verified Position Paper is

not intended to delay the proceedings but only occasioned by the above
justifications that would redound to a more enlightened and balanced
determination of the cases on their Tespective merits.

PRAYER

THEREFORE, premises considered, it is respectfully prayed of the

Honorable Office that leave sought by this Public Respondent be
GRANTED and the attached copy of Reply to the Joint Position Paper
dated October 0 1, 20 10 be ADMITTED to form part of the records of the
case.

FURTHER A2f D OTHER eQuitable reliefs are likewise prayed for.

Las Pinas City for Quezon City, Metro Manila, 05 November 20 10.

ANGELITO W. CHUA LAW OFFICE

Counsel for Respondent Cayton

Block 14, Lot 1, G. Diaz St.,corner Aurora

.iiuan
. BF Resort

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