References: Professor Harry L. Roque 09175398096,
Atty. Romel R. Bagares 09328798422 or Atty. Ethel C. Avisado 09177055431
Please click here for a .doc copy of the MOTION FOR VOLUNTARY DEPORTATION filed today by Jennifer Laude’s fiance, Marc Sueselbeck.
REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
BUREAU OF IMMIGRATION
BOARD OF SPECIAL INQUIRY
In re Deportation Charges
D.C. No. SBM-14-10/26-783
Art. 2711, Sec. 69
Watch List Order No. SBM-14-778
MOTION FOR VOLUNTARY DEPORTATION
RESPONDENT MARC SUESELBECK, through counsel, and unto this Honorable Office, respectfully states:
1. On 26 October 2014, a charge of undesirability was made against Respondent at the instance of Armed Forces of the Philippines Chief of Staff, Gen. Gregorio Pio P. Catapang, based on the events of 22 October 2014 at Camp Aguinaldo, Quezon City. Subsequently, Respondent was placed under the Bureau of Immigration Watch List No. SBM/BOC-14-778.
2. Pursuant to the Watch List, Respondent, a German national, was barred from leaving the Philippines even though he was scheduled to do so on 26 October 2014 on board Malaysian Airlines flight MH 0803, at 6:30 p.m., out of NAIA Terminal 1.
3. His German passport, with No. C689C1W4, was also confiscated.
4. Yesterday, after undersigned counsel informed him of the formal charges filed against him before this Honorable Office, he received word from his employer in Germany that he has to report for work by Monday next week, Nov. 3, 2014, or risk losing his job and paying liquidated damages for failing to perform certain provisions in his employment contract.
5. Thus, with a heavy heart – as he desires to defend himself against the charges leveled against him by Gen. Catapang – he manifests before this Honorable Office that he is seeking voluntary deportation the soonest time possible so he can attend to his only source of livelihood.
6. While he desires to leave the country immediately for that purpose and if allowed, he manifests that he will do so not later than this coming Saturday, November 1, 2014.
WHEREFORE, premises considered, Respondent prays that this Honorable Office issue an Order:
(a) granting his request for Voluntary Deportation and allowing him to fly out of the country as soon as practicable;
(b) deleting his name and other personal details from Watch List Order No. SBM/BOC-14-778; and
(c) returning to his possession without delay his German Passport as described above and earlier seized by immigration authorities.
Other relief just and equitable are also prayed for.
Makati City for City of Manila ; 19 October 2014.
ROQUE& BUTUYAN LAW OFFICES
1904 Antel 2000 Corporate Centre
121 Valero Street, Salcedo Village
Makati City 1200
Tel. Nos. 887-4445/887-3894
Fax No: 887-3893
H. HARRY L. ROQUE, JR.
Roll No. 36976
PTR No. 4264493/Jan 30, 2014/Makati
IBP No. 01749/Lifetime
MCLE Exemption No. IV-000513
(issued on Feb 15, 2013)
ROMEL R. BAGARES
Roll No. 49518
PTR No. 4264492/Jan 30, 2014/Makati
IBP No. 961461/Jan 29, 2014/Socsargen
MCLE Compliance No. IV-017519
(issued on Jan 25, 2013)
ETHEL C. AVISADO
Roll No. 56254
PTR No. 4281935/Feb 12, 2014/Makati
IBP No. 961251/Jan 27, 2014/Davao
MCLE Compliance No. IV-019563
(issued on May 2, 2013)
With my conformity: