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    Motion To Admit Position Paper

    Uploaded by

    Jose Cabrera Jr
    This document is a motion filed by Crown Regency Hotel & Towers' legal counsel requesting that the court admit a position paper on behalf of their client. The motion explains that the hotel was unaware their case was in default as they believed a lawyer was representing them. They ask to present evidence in their defense and for a chance to respond to the termination complaint, arguing there were legitimate reasons for firing the employee and due process was followed. The counsel requests the court admit the position paper in the interest of fairness and justice.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Motion To Admit Position Paper

    Uploaded by

    Jose Cabrera Jr
    3K views3 pages
    This document is a motion filed by Crown Regency Hotel & Towers' legal counsel requesting that the court admit a position paper on behalf of their client. The motion explains that the hotel was unaware their case was in default as they believed a lawyer was representing them. They ask to present evidence in their defense and for a chance to respond to the termination complaint, arguing there were legitimate reasons for firing the employee and due process was followed. The counsel requests the court admit the position paper in the interest of fairness and justice.

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    position paper

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    motion to admit position paper

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    This document is a motion filed by Crown Regency Hotel & Towers' legal counsel requesting that the court admit a position paper on behalf of their client. The motion explains that the hotel was unaware their case was in default as they believed a lawyer was representing them. They ask to present evidence in their defense and for a chance to respond to the termination complaint, arguing there were legitimate reasons for firing the employee and due process was followed. The counsel requests the court admit the position paper in the interest of fairness and justice.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    3K views3 pages

    Motion To Admit Position Paper

    Uploaded by

    Jose Cabrera Jr
    This document is a motion filed by Crown Regency Hotel & Towers' legal counsel requesting that the court admit a position paper on behalf of their client. The motion explains that the hotel was unaware their case was in default as they believed a lawyer was representing them. They ask to present evidence in their defense and for a chance to respond to the termination complaint, arguing there were legitimate reasons for firing the employee and due process was followed. The counsel requests the court admit the position paper in the interest of fairness and justice.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    You are on page 1of 3

    Republic of the Philippines

    NATIONAL LABOR RELATIONS COMMISSION


    Regional Arbitration Branch No. VII
    Cebu City

    ERICKSON M. TALLO
    Complainant,

    -versus- NLRC RAB-VII-CASE NO. 11-2254-16

    KANG CHOK SERVICES, INC./


    CROWN REGENCY HOTEL & TOWERS
    Respondents,
    x-------------------------------------------------------x

    MOTION TO ADMIT POSITION PAPER

    COMES NOW, Petitioner, through the undersigned counsel, and unto this

    Honorable Court most respectfully manifests that on January 26, 2016

    representatives from Crown Regency Hotel and Towers went to the NLRC to

    check on the status of the case and was surprised to find out that respondent

    Crown Regency Hotel and Towers was declared in default for having failed to

    attend the mandatory conciliation. Respondent was under the impression that a

    counsel represented this respondent and that a lawyer was attending for it

    during the hearings. Respondent is therefore constrained to engage the special

    entry of the undersigned for this purpose.

    In the interest of justice and fair play, it is humbly prayed that respondent

    be allowed to present evidence in its defense and that the Motion to admit

    Position paper be granted. There is a meritorious, legitimate and justifying

    reason for its failure to appear and file its pleadings on time even as the facts will

    bear out that there was neither abuse nor illegal reasons for the termination of

    the employment of the complainant. In fact, due process was accorded the

    complainant as the records will show.

    PRAYER
    WHEREFORE, premises considered, it is most respectfully prayed of this

    Honorable Court to ADMIT the Position Paper of respondent Crown Regency

    Hotel and Towers.

    Other relief and remedies fair and equitable under the premises are

    likewise prayed for.

    Respectfully submitted this February 6, 2017. Cebu City, Philippines.

    ______________________

    ______________________

    _______________________

    The Honorable Labor Arbiter


    NLRC

    SIR/MA’AM:

    Greetings! Kindly submit the foregoing motion to admit Position Paper to


    the Honorable Court on ______________ at 8:30 o’clock in the morning or
    immediately upon receipt thereof without further arguments or presence of
    counsel. Thank you very much.

    __________________

    EXPLANATION ON THE MODE OF SERVICE

    Due to the distance between the offices of the undersigned counsel and
    the following counsels of the parties and the lack of office personnel who could
    effect personal service, copies of the foregoing pleading were sent through
    registered mail.

    _________________________
    Copy Furnished:

    Erickson Tallo
    A. Tumulak St.
    Gun-ob, Lapu Lapu City
    _____________________
    _____________________

    Merlinda alvarez
    Kang chok Services Inc.
    Unit 25 The Atrium
    Andres Abellana St.,
    Guadalupe, Cebu City
    ___________________
    ___________________

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