REPUBLIC OF THE PHILIPPINES

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Quezon City

NADINE FAYE CANDELARIO MIRALLES,

Complainant,

-versus- NLRC Case No. NCR-07-11805-19

YUANTA SAVINGS BANK, PHILS./

CHONA BOYLES, MICHAEL SAMSON
CHUNG LUNG WU AND ALLEN WU,
Respondents.
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MOTION FOR EXTENSION OF TIME

TO FILE POSITION PAPER

Respondents, YUANTA SAVINGS BANK PHILIPPINES,

INC., CHONA BOYLES, MICHAEL SAMSON, CHUNG LUNG
WU and ALLEN WU, by the undersigned counsel, unto this
Honorable Office, respectfully states that:

1. On August 20, 2019, the Honorable Labor Arbiter Maria

Mylene P. Carag-Cruz directed the parties to submit their
respective Position Paper tomorrow or on August 30, 2019;

2. A draft of the Comment/Objections has already been

prepared. However, due to unrelenting pressure consisting of
preparation of pleadings and attendance in hearings in equally
important cases, the undersigned counsel anticipates that she will
be unable to file said Position Paper on August 30, 2019;

3. Hence, the undersigned counsel is respectfully

requesting for an extension of ten (10) days from August 30,
2019 or until September 9, 2019 within which to file said
Comment/Objections;

4. This motion is not intended for delay but is solely

dictated by the foregoing reasons.

PRAYER

PREMISES CONSIDERED, it is respectfully prayed of this

Honorable Office that respondents be granted an extension of
extension of ten (10) days from August 30, 2019 or until
September 9, 2019 within which to file their Position Paper.

Respondents pray for such other relief just and equitable

under the premises.

BELO GOZON ELMA

PAREL ASUNCION & LUCILA
Counsel for Respondents
15 & 16 Floors, Sagittarius Condominium
th th

H.V. De la Costa St., Salcedo Village

Makati City
Tel. Nos. 816-3716 to 19
Fax Nos. 817-0696; 812-0008
Email add: mail@bgepal.com
 By:

JESSALYN E. ECHANO
Roll No. 67907
PTR No.4774837 /06-16-2017/Quezon City
IBP No. 178669/05-18-2017/ Albay

COPY FURNISHED:

ATTY. NADINE FAYE CANDELARIO MIRALLES

18-G T-3 Little Baguio Terraces
N. Domingo, San Juan City

EXPLANATION

Due to distance and lack of available messengers, a copy of

the herein Motion was served upon the above-named party by
registered mail pursuant to Section 7, Rule 13 of the 1997 Rules
of Civil Procedure.

JESSALYN E. ECHANO