REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region Arbitration Branch
Quezon City

Hon. Raphael Kenneth E. Ybañez

JULIAN VICTOR MUTUC CONDA,

Complainant, NLRC-NCR Case No. 08-

01176-23
-versus-

BPM VISION PHILIPPINES, INC.,

BPM VISION PTY. LTD., and
PUNEET SODHI
Respondents.
x ------------------------------------------------- x

MOTION
(For: Extension of Time to File Amended Complaint)

Complainant, JULIAN VICTOR M. CONDA (“Complainant”),

through the undersigned counsel, unto this Honorable Office, most respectfully
avers that:

1. On 22 December 2023, the Complainant received the Order dated

15 December 2023 issued by this Honorable Office, requiring the Complainant
to submit, within ten (10) days from receipt, the amended Complaint.

2. Considering the public holidays during the ten (10) day period given
by this Honorable Office, not to mention the lack of sufficient manpower at the
office of the undersigned, the latter humbly prays for this Honorable Office to
extend the deadline of the filing of the Complainant’s Amended Complaint.

3. Consequently, the Complainant, through the undersigned counsel,

most respectfully requests for an additional period of ten (10) days from 2
January 2023 or until 12 January 2023, within which to file the Amended
Complaint.

4. This Motion is being filed solely for the foregoing reasons and is not
intended to delay the proceedings of the instant case.

RELIEF
 WHEREFORE, premises considered, it is respectfully prayed that the
Honorable Office grant the instant Motion, thereby giving the Complainant
additional ten (10) days from 2 January 2023 or until 12 January 2023, within
which to file his Amended Complaint.

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

Quezon City, 2 January 2023.

GIMENEZ, EUBANK, CRUZ, AND OCAMPO LAW OFFICES

Counsel for the Complainant
71A Congressional Avenue, Quezon City
Email: info@gecolawfirm.com.com
Telephone No. (02) 8641-6540

By:

ARVIN EDUARD H. CRUZ

Roll of Attorneys No. 73525
PTR No. 1749321 / 01.02.2024 / Quezon City
IBP OR Number Pending/ 01.02.2024 / Quezon City Chapter
MCLE Compliance No. VII - 0022289

Copy furnished:
Atty. Mary Judith B. Encarnacion,
Atty. Joseph G.M. Franco,
And Atty. Feliz Pascual
Counsel for Respondents – BPM Vision Philippines, Inc.
and Mr. Pueett Sodhi
1106, 11/F Tektite Towers, East Exchange Road
Ortigas Center, Pasig City, Metro Manila