Motion for Physical
Examination of Person

MOTION

COMES NOW the movant by the undersigned attorney, and unto this Honorable Court, respectfully avers:

1. That the movant is the defendant in the above-entitled criminal case for serious physical injuries;

2. That the offended party is at present confined in the Philippine General Hospital, alleged to have received physical injuries which would cause said offended party an illness for more than 30 days, according to the medical report of Dr. _____________________;

3. That the movant believes that the medical report on the extent and nature of the wounds received by the said offended party was exaggerated, and that the latter is feigning to be seriously ill in the hospital in order to magnify the crime alleged to have been committed by movant.

4. That the real extent and nature of the offended party's wound is in controversy in this case;

5. That Dr. __________________is a government physician, competent and impartial, who could make an -unbiased physical examination of the person of the offended party for the purpose of determining the true extent and nature of such wounds;

6. That such physical examination could be made during business hours of the day on ____________________ , 19_____, in the Philippine General Hospital.

WHEREFORE, it is respectfully prayed that in the interest of justice, an order for physical examination of the offended party be issued by this Honorable Court at the time, place, and manner above indicated.

_____________, this _______ day of ____________, 19_____.

                                                                                                   ___________________________ 
                                                                                                                  
(Attorney for the Defendant) 

                                                                                                    ___________________________
                                                                                                                                     
(Address)


NOTICE OF HEARING

To: (To the party to be examined
and to all other parties)
______________________________

                (Address)

Greetings: Please take notice that on Saturday ____________ 19_____ , at 9:00 o'clock A.M., or as soon thereafter as counsel may be heard, the undersigned will ask the Court of ______________ to approve the foregoing motion.

                          __________________________________
                                  
(Attorney for the Defendant)

RECEIVED COPY this __________ day

Of  _____________________ , 19 _____
_________________________________




________________________________
                     (Adverse party)

_________________________________
                          (Address)