Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City

GLORIA TABIANO ONG, ET AL.,

Complainant,

-versus- NLRC-NCR CASE No. 12-

00756-21
G.T.R. LION SECURITY
SERVICES,
Respondents,

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MOTION FOR EXTENSION OF TIME TO FILE POSITION PAPER

Respondents, G.T.R. LION SECURITY SERVICES, pro

se, most respectfully states that:

1. On ____________, Respondents received a copy of the

Complaint requiring to file our Position Paper on or before 31 March
2022 from receipt;

2. Due to the tremendous pressure, heavy volume of work,

numerous urgent meetings with clients and other equally important
matters being handled and attended to, Respondents were only able
to secure the services of the legal counsel on 27 March 2022;

3. Upon conferring with the counsel, Respondents were

advised to seek the Honorable Arbiter’s compassionate indulgence
and approval to grant herewith the Respondents for an extension of
fifteen (15) days to submit the Position Paper;

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

the case but is solely necessitated for the reasons stated above.
 WHEREFORE, Respondents respectfully prayed of unto this
Honorable Office that it be given a period of fifteen (15) days from
30 March, 2022 or until 14 April, 2022 to file its Position Paper.

Other reliefs just and equitable under the premises are likewise
prayed for.

Quezon City, Philippines, 29 March 2022.

G.T.R. LION SECURITY

SERVICES
RESPONDENTS

BY:

LEO N. RIMANDIMAN SR.__

President and General Manager