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NLRC - Motion To Admit Postn PPR

This document is a "Motion to Admit Position Paper" filed by a complainant in a labor case. It requests that the complainant be allowed to submit their position paper on February 5th, which is later than the original deadline, due to challenges in securing new employment and legal counsel. It argues that there are legitimate and justifying reasons for missing the deadline. It prays that the position paper be admitted and that other fair remedies be granted.

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Francis Bunye
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1K views3 pages

NLRC - Motion To Admit Postn PPR

This document is a "Motion to Admit Position Paper" filed by a complainant in a labor case. It requests that the complainant be allowed to submit their position paper on February 5th, which is later than the original deadline, due to challenges in securing new employment and legal counsel. It argues that there are legitimate and justifying reasons for missing the deadline. It prays that the position paper be admitted and that other fair remedies be granted.

Uploaded by

Francis Bunye
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City

______________________,
Complainant,

-versus-
NLRC-NCR CASE No. __________

_____________________
Respondent.

x--------------------------------------x

MOTION TO ADMIT POSITION PAPER

COMES NOW, Petitioner, pro se, and unto this Honorable

Office, most respectfully manifests that on January 29, 2020, my

representative filed a Final Motion for Extension of Time to File

Position Paper the reason being that due to the tremendous pressure

of securing a new employment being the family’s breadwinner,

coupled with the challenges of obtaining the services of a legal

counsel, the undersigned was constrained to seek the compassionate

consideration of this Honorable Office to allow her to file her Position

Paper on or February 5, 2020.

In the interest of justice and fair play, it is humbly prayed that

complainant be allowed to submit her position paper and that the

Motion to admit Position paper be granted. There is a meritorious,

legitimate and justifying reason for its failure to appear and file its

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pleadings on time even as the facts will bear out that there was an

abuse and illegal reasons for the termination of the employment of

the undersigned complainant.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Office to ADMIT the Position Paper of

undersigned complainant.

Other relief and remedies fair and equitable under the premises

are likewise prayed for.

Respectfully submitted this February 3, 2020. Quezon City,

Philippines.

_________________________
No.____, _____________Street,
SSS Village, Concepcion Dos, Marikina

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The Honorable Labor Arbitration Attaché
National Labor Relations Commission
Quezon City

MA’AM:

Greetings! Kindly submit the foregoing motion to admit Position


Paper to the Honorable Court on February 4, 2019 at 8:30 o’clock in
the morning or immediately upon receipt thereof without further
arguments or presence of complainant or representative. Thank you
very much.

_____________________

EXPLANATION ON THE MODE OF SERVICE

Due to the distance between the offices of the undersigned


complainant and the following counsels of the parties and the lack of
office personnel who could effect personal service, copies of the
foregoing pleading were sent through registered mail.

_____________________

Copy Furnished:

______________________, INC. RR NO.___________________


c/o Ms. _____________
Ms. ____________ DATE________________________
_____________________,
_____________________, AT___________________________
Bonifacio Global City (BGC), Taguig

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