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Motion To Admit

This document is a motion filed with the National Labor Relations Commission Regional Arbitration Branch No. 1 in the city of San Fernando, La Union, Philippines. The motion requests admission of a position paper in a case between complainant Archie A. Mater and respondent Kingpost Corporation and/or Mary Antoinette C. Dacanay regarding a request for separation pay. The motion states that the parties were unable to reach an agreement during mediation proceedings and agreed to submit position papers, but the complainant experienced difficulty obtaining legal counsel until recently. The motion requests that the position paper be admitted on grounds that the filing is done in good faith and not to delay proceedings.

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Joseph Santos Gacayan
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688 views

Motion To Admit

This document is a motion filed with the National Labor Relations Commission Regional Arbitration Branch No. 1 in the city of San Fernando, La Union, Philippines. The motion requests admission of a position paper in a case between complainant Archie A. Mater and respondent Kingpost Corporation and/or Mary Antoinette C. Dacanay regarding a request for separation pay. The motion states that the parties were unable to reach an agreement during mediation proceedings and agreed to submit position papers, but the complainant experienced difficulty obtaining legal counsel until recently. The motion requests that the position paper be admitted on grounds that the filing is done in good faith and not to delay proceedings.

Uploaded by

Joseph Santos Gacayan
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
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Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. 1
City of San Fernando, La Union

ARCHIE A. MATER
Complainant/s,

-versus- NLRC CASE NO. RAB-I


01-1009-19 (LU-1)

KINGPOST CORPORATION and/or


MARY ANTOINETTE C. DACANAY
Respondent/s

x------------------------------------------------------------------x
MOTION TO ADMIT POSITION PAPER
COMPLAINANT, through the undersigned Counsel unto this Honorable
Commission, respectfully state:
1. That there was a proceeding held on February 7, 2019 for the purpose of
amicably settling my request for separation pay from the Respondent;
2. That there was no agreement arrived during the proceedings;
3. That the parties agreed to submit positions papers;
4. That the Complainant experienced difficulty in engaging the services of a
counsel for this case;
5. That only last April 29, 2019 that he was able to engage the services of a
counsel; and
6. That the filing of this motion is done in good faith and not for purposes of
delaying the proceedings of this case but for the reason above-stated.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the


Honorable Commission that this Motion, praying for the admission of my
Position Paper , be granted.

City of San Fernando, La Union, this ___________ day of May 2019.

ATTY. JOSEPH S. GACAYAN


Counsel for the Complainant
Roll No. 65790/June 21, 2016
PTR No. 1348772/Jan. 9, 2019/CSFLU
LU IBP OR No. 068384/Jan. 10, 2019
MCLE Compliance No. VI-0003087 valid until
192 Purok 4 Biday, City of San Fernando
2500 La Union

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