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Motion For Postponement of Submission of Position Paper: Regional Arbitration Branch No. Iii

The motion requests a 10-day postponement of the submission of a position paper in a labor case between Danilo Mationg and Alvan Oliveros. The position paper was originally due on June 30, 2017. The respondent's counsel requests more time to collate documents and information for the case. Counsel is also juggling other pending cases. The motion asks the labor arbiter to favorably consider the 10-day extension request.

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36 views

Motion For Postponement of Submission of Position Paper: Regional Arbitration Branch No. Iii

The motion requests a 10-day postponement of the submission of a position paper in a labor case between Danilo Mationg and Alvan Oliveros. The position paper was originally due on June 30, 2017. The respondent's counsel requests more time to collate documents and information for the case. Counsel is also juggling other pending cases. The motion asks the labor arbiter to favorably consider the 10-day extension request.

Uploaded by

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

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
REGIONAL ARBITRATION BRANCH NO. III
City of San Fernando, Pampanga

DANILO D. MATIONG
Complainant,
-versus- NLRC Case No.
ALVAN OLIVEROS
Respondents.
x-----------------------------------x

HON. Labor Arbiter LEANDRO M. JOSE

MOTION FOR POSTPONEMENT OF SUBMISSION OF POSITION PAPER

RESPONDENTS, by counsel, to this Honorable Office, most respectfully move and state:

1) That the above titled case is set for submission of position papers on June 30, 2017 at 10 am;
However, Respondents is still collating documents and information relative to the case of
Complainant and will need an additional period of ten (10) days counted from June 30, 2017
within which to file the position paper on behalf of respondents.

2) In this regard, undersigned counsel without wanting to delay this case but because of other
equally pending cases and for the reason stated above respectfully requests an additional ten
(10) days counted from June 30, 2017 within which to file the Position paper to the above
captioned complaint.

PRAYER

IN VIEW OF THE FOREGOING, it is respectfully prayed of this Honorable Office that the
forgoing Motion for Postponement of Submission of Position Paper be favorably considered

RESPECTFULLY SUBMITTED.

Quezon City for San Fernando, Pampanga

June 27, 2017.

By:

ATTY. ALVAN STEPHENSON G. OLIVEROS


(COUNSEL FOR THE RESPONDENTS)
PTR No. 5550996; 06-08-2017; Pasay City
ROLL OF ATTORNEYS No. 69997
IBP Member No. 001801 (Malabon City)
MCLE Exempted (Admitted to the Bar – 2017)
1
Copy furnished:

DANILO D. MATIONG
(Complainant)

10 Brgy. Saguin, Mc Arthur Highway, 2000, City of San Fernando, Pampanga

EXPLANATION

A copy of the foregoing MOTION was served the respondents via PRIVATE COURIER SERVICES
(LBC) due to the distance and time constraints.

Atty. Alvan Stephenson G. Oliveros

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