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    Motion To Admit

    Uploaded by

    Joseph Santos Gacayan
    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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    © All Rights Reserved
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    Motion To Admit

    Uploaded by

    Joseph Santos Gacayan
    558 views1 page
    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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    Motion to Admit Position Paper

    Original Title

    Motion to Admit

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    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.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    558 views1 page

    Motion To Admit

    Uploaded by

    Joseph Santos Gacayan
    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.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    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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