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Motion For Extension (SAMPLE)

Jake Bryson R. Dancel filed a motion for a 30-day extension to file a position paper in response to a labor case against his former employer IQOR Philippines and two individuals. Due to the complexity of the issues and lack of sufficient time and money, Dancel was unable to procure legal counsel to assist in preparing his position paper by the original deadline of November 13, 2015. In the interest of substantial justice, Dancel requested an additional 30 days from receipt of the motion to adequately prepare and file his position paper for the case.

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Jake Bryson Dancel
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6K views

Motion For Extension (SAMPLE)

Jake Bryson R. Dancel filed a motion for a 30-day extension to file a position paper in response to a labor case against his former employer IQOR Philippines and two individuals. Due to the complexity of the issues and lack of sufficient time and money, Dancel was unable to procure legal counsel to assist in preparing his position paper by the original deadline of November 13, 2015. In the interest of substantial justice, Dancel requested an additional 30 days from receipt of the motion to adequately prepare and file his position paper for the case.

Uploaded by

Jake Bryson Dancel
Copyright
© © All Rights Reserved
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION


Regional Arbitration Branch No. III
City of San Fernando, Pampanga

JAKE BRYSON R. DANCEL,


Complainant,

RAB III Case No. 10- 23346- 15

-versusIQOR PHILIPPINES,
MS. JULIET GESLANI, and
MS. ARLENE GANDEZA
Respondents,
x---------------------x
MOTION FOR EXTENSION OF
TIME TO FILE POSITION PAPER
COMPLAINANT, by

himself,

unto

this

Honorable

Office,

most

respectfully state that:


1. On November 13, 2015, we were required to file a position paper for
and in consideration of our case;
2. Due to the complexities of the issues revolving the case, the
undersigned needed the assistance of a counsel to present his case;
3. The undersigned exerted diligent efforts to procure the services of a
counsel;
4. However, due to lack of sufficient time and money, the undersigned
failed to procure the services of a counsel. The undersigned even
tried to turn to the Public Attorneys Office but he could not qualify;
and
5. Thus, in the interest of substantial justice, the undersigned would like
to ask for another thirty (30) days to adequately prepare his position
paper.
WHEREFORE, above premises considered, it is humbly prayed unto
this Honorable Office, that the undersigned would be given another thirty (30)
days from the receipt of this motion to file his position paper.
Other just and equitable remedy under the premises are equally prayed
for.
Done this 4th of December at San Fernando City, Pampanga.

JAKE BRYSON R. DANCEL


Complainant

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