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Motion For Extension

The complainant Enrique Addatu filed an urgent motion for an extension of time to submit his position paper. His counsel needs more time to obtain amplification documents related to the overseas medical report issued to Mr. Addatu. These documents pertain to the source or root documents leading to the medical report. Counsel is also still securing clearer copies of some local documents. The motion requests a two-week extension from the date of filing to submit the position paper.

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Atty. Emmanuel Sandicho
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1K views2 pages

Motion For Extension

The complainant Enrique Addatu filed an urgent motion for an extension of time to submit his position paper. His counsel needs more time to obtain amplification documents related to the overseas medical report issued to Mr. Addatu. These documents pertain to the source or root documents leading to the medical report. Counsel is also still securing clearer copies of some local documents. The motion requests a two-week extension from the date of filing to submit the position paper.

Uploaded by

Atty. Emmanuel Sandicho
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines
Department of Labor and Employment
NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City


OFW-SEA BASED
ENRIQUE T. ADDATU, NLRC CASE NO. [M] NCR-01-000831-14
Complainant, HON. LABOR ARB. CLARISSA B. LERIOS

- versus

ALL OCEANS MARITIME
AGENCY, INCORPORATED,
ORIENT OVERSEAS CON-
TAINER LINE, LTD., and/or
ROGELIO T. BALQUIN,
Respondents.
x-----------------------------------x


URGENT MOTION FOR
EXTENSION OF TIME
FILE POSITION PAPER


COMPLAINANT ENRIQUE TALADTAD ADDATU, by
undersigned counsel, most respectfully moves for Extension of
Time To File complainants Position Paper due to the following
pressing reasons, to wit

1. Undersigned counsel is exerting some final efforts to get
amplification documents on the overseas medical report
issued to the complainant Mr. Addatu. These amplification
documents pertain to source or root documents leading the
medical report. Mr. Addatu will have to secure these
documents from the source since the local representatives
are not so cooperative.

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3. Clearer copies of some local documents are still being
secured.

RELIEF SOUGHT

WHEREFORE, in the higher interest of substantive
adjudication and justice in the above-captioned case, it is most
respectfully sought from this Honorable Arbitration Office that
an extension of time to file Position Paper be accorded within
two (2) weeks from today.

Other reliefs just and equitable are respectfully sought.

MOST RESPECTFULLY SUBMITTED.
Santa Cruz, Laguna and Quezon City, 03 April 2014.


Atty. EMMANUEL E.
SANDICHO
Counsel for the Complainant Mr. Addatu
Casalda Seamans Welfare Advocates, Phils.,
(CSWAP) Rm. 402 Web-Jet Building, No. 64
Quezon Avenue corner BMA Avenue, Quezon
City, E-mail address: [email protected]
IBP No. 941754, 03 January 2014, Laguna
PTR No. 1653109, 03 January 2014, Laguna
Roll No. 42246 admitted on 9 May 1997
MCLE Compliance Period No. IV-00021894

Copy furnished:

Counsel For the Respondents
________________________________
3
rd
Floor Mary Bachrach Bldg.,
25
th
Street, Port Area, Manila

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