Motion To Reset
Motion To Reset
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Republic of the Philippines
Department of Labor and Employment
NATI ONAL LABOR RELATI ONS COMMI SSI ON
National Capital Region
Quezon City
OFW-SEA BASED
ENRI QUE T. ADDATU, NLRC CASE NO. [M ] NCR-0 1 -0 0 0 8 31 -1 4
Complainant, HON. LABOR ARB. CLARI SSA B. LERI OS
- versus
ALL OCEANS M ARI TI M E AGENCY
I NCORPORATED, ORI ENT OVER-
SEAS CONTAI NER LI NE, LTD., AND
ROGELI O T. BALQUI N,
Respondents.
x-----------------------------------x
URGENT MOTI ON TO
RESET CONFERENCE
COMPLAINANT ENRIQUE T. ADDATU, by undersigned
counsel, most respectfully moves for One Resetting of the
Mandatory Conference due to the fact that undersigned counsel
is presently indisposed due to joint-swelling in the right ankle
caused by gout; and due to over-fatigue caused by out-of-town
traveling during the past several days.
WHEREFORE, in view of these circumstances, it is most
respectfully sought from this Honorable Arbitration Office that
one resetting of the conference be accorded until 11 March 2014.
It is further respectfully sought that respondents be obliged
to furnish the complainant with his own complete medical
records as it is only just and rightful that complainant be given
copies of such medical records pertaining to respondents kept
findings of his condition.
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Other reliefs just and equitable are respectfully sought.
MOST RESPECTFULLY SUBMITTED.
Santa Cruz, Laguna and Quezon City for the NLRC-NCR
Arbitration Branch, this 26 February 2014.
At t y. EMMANUEL E. SANDICHO
Counsel for the Complainant Mr. Addatu
Casalda Seamans Welfare Advocates, Phils.,
(CSWAP) Rm. 402 Web-Jet Building, No. 64
Quezon Avenue corner BMA Avenue, Quezon
City, E-mail address: [email protected]
IBP No. 941754, 03 January 2014, Laguna
PTR No. 1653109, 03 January 2014, Laguna
Roll No. 42246 admitted on 9 May 1997
MCLE Compliance Period No. IV-00021894
Copy furnished:
Counsel f or Respondent s
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