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Motion for Extension to File Position Paper

This document is a "Motion for Extension of Time to File Position Paper" submitted to the National Labor Relations Commission Regional Arbitration Branch No. IV in Calamba City, Philippines. The motion requests a 15-day extension, until December 5, 2019, to submit a Position Paper in response to a previous order requiring its filing by November 21, 2019. It states that the lawyer needs more time due to the volume of other urgent commitments and cases. The motion is being filed to request the extension and not to delay the case.

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John Sowp MacTavish
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282 views2 pages

Motion for Extension to File Position Paper

This document is a "Motion for Extension of Time to File Position Paper" submitted to the National Labor Relations Commission Regional Arbitration Branch No. IV in Calamba City, Philippines. The motion requests a 15-day extension, until December 5, 2019, to submit a Position Paper in response to a previous order requiring its filing by November 21, 2019. It states that the lawyer needs more time due to the volume of other urgent commitments and cases. The motion is being filed to request the extension and not to delay the case.

Uploaded by

John Sowp MacTavish
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
  • Motion for Extension to File Position Paper

Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. IV
Calamba City

HON. MARIA ANA T. ADVENTO


Labor Arbiter

ARCINAL S. SINGUA JR. ET. AL.,


Complainants,

-versus- NLRC NCR CASE NO. RAB IV 09-


01601-19-C

LEARN AND TALK ENGLISH TUTORIAL


CENTER CO. ET. AL.,
Respondents.
x------------------------------------------------------x

MOTION FOR EXTENSION OF TIME


TO FILE POSITION PAPER

COMES NOW Complainants, by the undersigned counsel, unto this


Honorable Court, most respectfully state:

1. That on 11 November 2019, this Honorable Office required the


Complainants to file a Position Paper within ten (10) days or on
21 November 2019;

2. However, due to the volume of equally urgent commitments


and important cases, the undersigned counsel cannot comply
with the order of this Honorable Office to file a Position Paper
on 21 November 2019 and will need an additional number of
days to prepare and submit the same;

3. That as such, undersigned counsel is


constrained to request for an additional period of fifteen (15)
days from today within which to fully comply with the
Honorable Office’s order;
Page |2

4. This motion is being filed due to abovementioned reasons and


not for the purpose of delaying the instant case.

PRAYER

WHEREFORE, PREMISES CONSIDERED, the undersigned


most respectfully prays of this Honorable Office that the
Complainants be given an additional period of thirty (15) days
from today or until 05 December 2019 within which to submit their
Position Paper.

Other reliefs just and equitable under the premises are also
prayed for.

Dasmarinas City for Calamba Laguna, 20 November 2019.

JORDAN D. VILLOTA
Counsel for Complainants
Rm. 13, 2nd floor De Castro Building
Aguinaldo Highway
Imus, Cavite
Roll No. 69866
PTR No. /1095420/1.04.2019/Imus City
IBP No. /060502/1.04.2019/ Cavite Chapter
MCLE Compliance No. VI-00113961

EXPLANATION ON SERVICE BY REGISTERED MAIL

Respondent, by Counsel, in compliance with Section 11, Rule 13 of


the 1997 Rules of Civil Procedure of the Rules of Court, respectfully
states that due to distance to effect personal service, a copy of this
Motion For Extension dated 20 November 2019 was served by
registered mail upon the Petitioner pursuant to Section 7, Rule 13 of
the said Rules.

Copy Furnished:

LEARN AND TALK ENGLISH TUTORIAL CENTER CO.


B2 L2 2ND FLOOR, UNIT D,
JLASJ BLDG., GOV DRIVE,
BRGY. MANGGAHAN, GEN. TRIAS

1 Valid until April 14, 2022

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