Frey Fil MFE

 

Republic of the Philippines Department of Labor and Employment E mployment NATIONAL LABOR RELATIONS COMMISSION National Capital Region Quezon City  ARNOLD E. DAGURO, et al.

Complainants ,

- versus -

NLRC NCR CASE NO. 12-00995-19 12-00995-19

FREY FIL CORP.  Respondent . x---------------------x--------------------------------x -----------x

NOTICE OF APPEARANCE WITH MOTION FOR EXTENSION OF TIME TO FILE POSITION PAPER OF COMPLAINANT Complainants Gaudencio M. Banayad, Mardy D. Martirez, Reny Boy P. Nepacina, Renier B. Salva, Jessie S. Solinap, Christopher L. Mariano, Orlando S. Lambus, Fil Am T. Amahit, Maria Cristina C. Layson, and Dalmacio V. Dela Cruz, by and through the undersigned counsel and unto this Honorable Commission, most respectfully avers: 1.  That the services of the undersigned counsel was contracted only last Wednesday, February 5, 2020. 2.  That complainants were ordered to submit Position Paper on February 10, 2020; 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 today or until February 20, 2020 within which to submit complainants’   Position Paper. Moreover, this additional time will also allow the undersigned to study this case further  and in fact, there are other documents that he is requiring which are not yet available; 5.  This Motion is not intended for delay but solely due to the foregoing reasons. 1

 

PRAYER WHEREFORE, it is most respectfully prayed of this Honorable Commission that complainants be allowed extension of time to submit Position Paper.

Respectfully submitted. Makati City for Quezon City, February 10, 2020. H.T. VILLEGAS LAW OFFICE Unit C 3rd Floor LTA Bldg., 118 Perea St., Legaspi Village Makati City Tel No. (02) 8451039

By: KENN HENRI C. VILLEGAS

Privilege Tax Receipt No. 6988095 January 31, 2020, Iloilo City IBP Receipt No. 087172 May 10, 2019, Pasig City Roll No. 73221, June 18, 2019 MCLE Compliance Certificate No. VI  – (exempt)

Copy furnished:

FREY FIL Corp. 83 West Ave., Brgy. Paltok, San Francisco Del Monte, Quezon City 

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