Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
REGIONAL ARBITRATION BRANCH NO. IV
CALAMBA CITY
Francis Hernandez, Francis Pardo
and Nolly Gonzaga
Complainant,
NLRC
CASE
NO.
RAB-IV 02-00282-14-L
-versusToshiba Information Equipment
(Phils.) Inc., Romel Carpio and
Masahori Ichihara
Respondents,
x-------------------------------------------x
MOTION FOR EXTENSION TO FILE
RESPONDENTS POSTION PAPER
Respondents TOSHIBA INFORMATION EQUIPMENT (PHILS.)
INC, ROMEL CARPIO and MASAHORI ICHIHARA (hereafter
collectively referred to as Respondents), by counsel, unto this
Honorable Office, most respectfully state that:
1.

This Honorable Office has set the date for the filing of the
Respondents position paper on 29 April 2014.

2.

The undersigned counsel has already started drafting its pleading but
due to heavy volume of work, which consists of drafting other
pleadings in other equally important cases being handled, attendance
at hearings, numerous meeting with clients and preparation of various
legal documents, he was unable to finalize respondents position
paper.

3.

Thus, Respondents are constrained to request for a period of fifteen

(15) days from 29 April 2014 or until 14 May 2014 to file its position
paper or any other pleading.

4.

This Motion is not intended to delay the proceedings in the case but
is solely necessitated for the reasons stated above.
PRAYER
WHEREFORE, Respondents respectfully prays for this
Honorable Office that it be given a period of fifteen (15) days from 29
April 2014 or until 14 May 2014 to file its position paper or any other
pleading.
Other just and equitable reliefs are likewise prayed for.
Taguig City for Calamba City, 29 April 2014.

BATUHAN BLANDO CONCEPCION AND

TRILLANA
Counsel for Respondents
th
15 floor, Picadilly Star Building, 4th Avenue cor.
27th St, Bonifacio Global City, Taguig City
15th Floor, Picadilly Star Building,
4th Ave., cor 27th Street
Bonifacio Global City, Taguig City
Telephone Number: 846-8004
Email Address: bbctlaw@bbclawoffice.net
bbcflaw@mydestiny.net
By:

JOSELITO JOHN G. BLANDO

PTR No. A-1971425, 2 January 2014; Taguig City
IBP No. 949610; 2 January 2014; Makati Chapter
Roll of Attorneys No. 38555

MCLE Compliance No. IV-0008786; 25 October

2012

JAMES BRYAN O. AGUSTIN

PTR No. A-1971431; 2 January 2014; Taguig
City
IBP No. 949615; 2 January 2014; Quezon City
Roll of Attorneys No.: 61525
MCLE Compliance No. IV-0013874; 27 March
2013

COPY FURNISHED:
Francis Pardo
Barangay Halang, Calamba City
Francis Hernandez
Poblacion San Luis, Batangas.
Nolly Gonzaga
San Vicente Sto. Tomas, Batangas.