Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. 1
City of San Fernando, La Union

ARCHIE A. MATER
Complainant/s,

-versus- NLRC CASE NO. RAB-I

01-1009-19 (LU-1)

KINGPOST CORPORATION and/or

MARY ANTOINETTE C. DACANAY
Respondent/s

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MOTION TO ADMIT POSITION PAPER
COMPLAINANT, through the undersigned Counsel unto this Honorable
Commission, respectfully state:
1. That there was a proceeding held on February 7, 2019 for the purpose of
amicably settling my request for separation pay from the Respondent;
2. That there was no agreement arrived during the proceedings;
3. That the parties agreed to submit positions papers;
4. That the Complainant experienced difficulty in engaging the services of a
counsel for this case;
5. That only last April 29, 2019 that he was able to engage the services of a
counsel; and
6. That the filing of this motion is done in good faith and not for purposes of
delaying the proceedings of this case but for the reason above-stated.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the

Honorable Commission that this Motion, praying for the admission of my
Position Paper , be granted.

City of San Fernando, La Union, this ___________ day of May 2019.

ATTY. JOSEPH S. GACAYAN

Counsel for the Complainant
Roll No. 65790/June 21, 2016
PTR No. 1348772/Jan. 9, 2019/CSFLU
LU IBP OR No. 068384/Jan. 10, 2019
MCLE Compliance No. VI-0003087 valid until
192 Purok 4 Biday, City of San Fernando
2500 La Union