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