REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR
NATIONAL LABOR RELATIONS COMMISSION
NATIONAL CAPITAL REGION
QUEZON CITY

________________________________
Complainant,
-versus- NLRC-NCR CASE NO.
______________
________________________________
Respondents.
x---------------------------------------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE POSITION PAPER

RESPONDENTS _________________, through undersigned counsel and

unto this Honorable Office, most respectfully manifests that:

1. On May 28, 2019, a hearing was conducted for the above-entitled case.
At the said hearing, the Honorable Arbiter ordered the parties to submit
their respective position paper on June 26, 2019.

2. However, due to heavy workload at the undersigned counsel’s law office

representing the respondents, counsel will not be able to submit the
respondent’s position paper on June 26, 2019. Hence, counsel is
constrained to move for an extension of time to file their position paper
on July 5, 2019 or at any other date after the aforesaid date at the
convenience of the Honorable Office.

3. This motion is not intended for delay but solely for the reasons
aforestated.

PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully prayed of

this Honorable Office that the respondents be allowed to submit their position
paper on July 5, 2019 or soon thereafter at the convenience of the Honorable
Office’s calendar.

Other just and equitable reliefs are also prayed for.

Paranaque City for Quezon City, June 25, 2019.

1
 ________________________
Counsel for the _____________________
(Office Address)
Tel. No. ______

By:

_____________________
PTR No. ______/1.10.19/Paranaque City
IBP No. _____/1.10.19/RSM
Roll No. _____
MCLE Compliance No. ________/5.24.18

FURNISHED WITH COPIES:

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