Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region Arbitration Branch
Quezon City

GERRY T. BISNAN,
Complainant,

-versus- NLRC-NCR Case No.11-16611-17

(Labor Arbiter RONALDO R. DOCTOR)

ALTO PLASTIC PACKAGING CORP.

and/or TINA VALENCIA and/or Sps.
ESTELITO and SUSAN JACINTO,
Respondents.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - x

MOTION FOR EXTENSION OF TIME TO FILE POSITION PAPER

and FORMAL ENTRY OF APPEARANCE

WITH UTMOST DEFERENCE TO THIS HONORABLE OFFICE,

Complainant, by the undersigned counsel, most respectfully states that:

1. Complainant engaged the services of undersigned only

recently;

2. An the hearing last 17 January 2018, both parties were

required to submit their respective Position Papers on 01 February 2018 at
10:00 o’clock in the morning;

3. However, due to the pressures of equally urgent professional

work and prior commitments, the undersigned counsel will not be
able to meet the said deadline;

4. As such, undersigned counsel is constrained to request for an

additional period of ten (10) days from receipt hereof within
which to submit Complainant’s Position Paper and other supporting
evidence. Moreover, this additional time will also allow the
undersigned to interview the available witness and study this instant case;

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 5. This Motion is not intended for delay but solely due to the
foregoing reasons;
6. Lastly, kindly enter the appearance of the undersigned as
counsel for the Complainant in the above-entitled case. Accordingly, it is
respectfully prayed that the undersigned be furnished copies of all
pleadings, orders or notices relative to the instant case at following
address:

ALAFRIZ DOMINGO BARTOLOME LACHICA AGPAOA

CALVAN CANTIL & CUSTODIO (ADBLACCC) Law Office
Unit 4-I, Future Point Plaza 3, No. 111 Panay Avenue,
Brgy. South Triangle, Quezon City 1103
Landline: (02) 935-4262 • Email: adblaccc@adblaccclaw.com

PRAYER

WHEREFORE, premises considered, Complainant most respectfully

prays unto this Honorable Labor Arbitration Office that he be given an
additional period of TEN (10) DAYS from receipt hereof within which to
submit his Position Paper and other documentary evidence. It is also prayed
that the foregoing Formal Entry of Appearance be duly NOTED.

Other relief, just and equitable are likewise prayed for.

Quezon City. 31 January 2018.

Atty. JASON A. CANTIL

Roll of Attorneys No. 56515
IBP Lifetime Member No. 011356; QC
MCLE Compliance No. V-017096; 03/21/2016
PTR No. 5520902; 01/03/2018; Quezon City
Contact No. 0917-3087689
Email: jac@adblaccclaw.com

JAMES CORWIN S. CUSTODIO

Roll of Attorneys No. 63741
IBP Lifetime No. 014198; 01/12/2016; RSM
MCLE Compliance No. V-0005492; 01/14/2015
PTR No. 5520904; 01/03/2018; Quezon City
Contact No. 0998-8514537
Email: jcc@adblaccclaw.com

COPY FURNISHED:

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ALTO PLASTIC PACKAGING CORP; TINA VALENCIA;
Spouses ESTELITO and SUSAN JACINTO
No. 81 Captain Cruz Steet, Parada, Valenzuela City

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