Motion To Quash SW CRIM PRO Finals
Motion To Quash SW CRIM PRO Finals
Motion To Quash SW CRIM PRO Finals
“You are hereby commanded to make an immediate search at any time of the day or night
of the said stall and its premises located at the address indicated above and forthwith seize and
take possession of the foregoing personal items, to wit:
All textbooks that published by Z Bookstore, Incorporation
and to make a return of the same to the undersigned to be dealt with in accordance with the
law.
2. With all due respect to the Honorable Court, the subject Search Warrant is null and void
and should be quashed on the following grounds:
a. That there exist no probable cause for the issuance of the search warrant. It is very
clear on the testimony of the witnesses that the respondent was a buyer in good faith of
the second-hand books.
b. That there is no law that is specifically punishing it and it is legal to sell second-hand
books so long as you sell them through a legal method.
Respondent prays for such other reliefs just and equitable on the premises.
Respectfully submitted.
EIMA TUMJAR
Counsel for the Respondent
PTR No. 9870689/1-2-15/Manila
IBP. No. 8989696/1-2-15/Manila
Attorney’s Roll No. 456,678