Republic of the Philippines

National Labor Relations Commission

NCR REGIONAL ARBITRATION BRANCH
Quezon City

NORHANIE M. FARISCAL,
Complainant,

NCR-RAB-08-04042-18
-versus-

STAR MAGIC PLACEMENT CO.

INC., DISTINCTION
RECRUITMENT and JOSE DELA
CRUZ
Respondents.
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MOTION TO ADMIT POSITION PAPER

Respondents Star Magic Placement Co. Inc. (Star Magic) and Jose
Dela Cruz, by counsel and unto this Honorable Office, most respectfully
seeks the admission of its Position Paper in the instant complaint, on the
following presentations, to wit:

1. Respondent was required to submit its Position Paper on 22

May 2019. However, due to equally important prior engagement of the
undersigned counsel, he was constraint to move for an extension of
additional seven (7) days or until 29 May 2019, which was granted by
the Honorable Labor Artbiter.

2. Unfortunately, on the scheduled submission, the messenger

of the respondent was stuck in traffic along South Luzon Expressway
(SLEX) causing the delay in the submission of Position Paper.

3. In view of the foregoing and in the interest of substantial

justice, respondent respectfully request, on bended knees, for the
admission of the attached Position Paper.

4. This Motion is not intended to delay the proceedings.

 RELIEFS

ACCORDINGLY, foregoing premises considered, Respondents

most respectfully pray that admission of the attached Position Paper.

Such other just and equitable reliefs or remedies under the

premises are likewise prayed for.

City of Sta. Rosa, Laguna for Quezon City, 29 May 2019.