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FILE NUMBER 288/2010

J. JESUS ESPARZA
VS
INFONAVIT

H. SPECIAL MEETING No. 24


OF THE FEDERAL CONCILIATION BOARD
AND ARBITRATION
P R E S E N T.

LICENCIADA MONCERRAT BARRERA LEDESMA, Apoderada


Legal de la C. MARIA DE LA LUZ RUELAS GAYTAN, Personality that I
accredit by means of Power of Attorney that I attach hereto (Annex 1),
indicating as domicile to hear and receive all kinds of notifications at Av.
Paseo Benedicto XVI 208 Int. 115 Fraccionamiento San Gerardo de la
Ciudad de Aguascalientes, we respectfully appear before this H. Board,
to expose:

That I come in the name and on behalf of my principal to


request this H. Board the DECLARATION OF BENEFICIARY in favor of
C. MARIA DE LA LUZ RUELAS GAYTAN, for the interests and labor
rights of her deceased husband J. JESÚS ESPARZA who worked for the
company ING AFORE, S.A DE C.V.

For further clarification of this request, the following facts and legal
precepts motivate the present document:

H E C H O S:

1.- The deceased employee C. J. JESÚS ESPARZA, worked for


ING AFORE, S.A DE C.V., domiciled at Av. Universidad number 1001
Torre Plaza Bosques Piso 3, Bosques del Prado of this city of
Aguascalientes.

2.- The employee C. J. JESÚS ESPARZA, died on AUGUST 9,


2010 of MESENTERIC TROMBOSIS. MULTIPLE ORGAN FAILURE.
HYDROELECTRIC UNBALANCE, as evidenced in the death certificate
with Folio Number 3181250. (Annex 2).
3.- The deceased worker is survived by his wife C. MARIA DE LA
LUZ RUELAS GAYTAN, who was an economic dependent and a direct
relative of the deceased worker, as evidenced by the marriage certificate
No. 1271 (Annex 3).

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4.- It is the case that on the occasion of the death of the worker J.
JESÚS ESPARZA, a resolution is requested to be issued in this H. Board
in order to declare our client C. MARIA DE LA LUZ RUELAS GAYTAN as
beneficiary of the interests and labor rights of the deceased worker,
derived from the employment relationship with the company ING AFORE,
S.A. de C.V.

DERECHO

As to the merits of the case, the provisions of Article 123, Section


"A" of the Political Constitution of the United Mexican States apply. With
respect to the Federal Labor Law, Articles 1, 2, 3, 8, 10, 16, 17, 18, 501,
502 and other relative and applicable articles of the aforementioned laws.

The procedure is governed by the provisions of Title Fourteen,


Chapter XVIII, Articles 982 to 991 of the Federal Labor Law.

In view of the foregoing, I hereby request that this H. Board:

FIRST.- To consider ourselves presented in the terms of


the present document with its annexes, requesting to declare as sole and
legitimate beneficiary of the interests and labor rights of the deceased
worker CELIA MABELI RIOS OLMOS in favor of our represented C.
CARLOS EDUARDO TELLEZ ISLAS, who worked for TELMEX S.A. DE
C.V., and once the resolution requested has been issued, please issue a
certified copy to the plaintiff, as well as the return of the documents
attached as evidence to this motion.

I OBJECT TO WHAT IS NECESSARY

Aguascalientes, Ags. November 20, 2012.

LIC. MONCERRAT BARRERA LEDESMA

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