Scribd Logo
Upload

Welcome to Scribd!

  • Motion To Reset

    Uploaded by

    Atty. Emmanuel Sandicho
    86 views2 pages
    The complainant's counsel filed an urgent motion to reset the mandatory conference due to being indisposed with gout in his right ankle and fatigue from recent travel. He requests to postpone the conference until March 11, 2014. Additionally, the motion asks the respondents to provide the complainant's complete medical records pertaining to the case, as the complainant has a right to access these documents. Other relief is also sought.

    Original Description:

    Motion To Reset

    Original Title

    Motion to Reset

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Report this Document
    The complainant's counsel filed an urgent motion to reset the mandatory conference due to being indisposed with gout in his right ankle and fatigue from recent travel. He requests to postpone the conference until March 11, 2014. Additionally, the motion asks the respondents to provide the complainant's complete medical records pertaining to the case, as the complainant has a right to access these documents. Other relief is also sought.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    86 views2 pages

    Motion To Reset

    Uploaded by

    Atty. Emmanuel Sandicho
    The complainant's counsel filed an urgent motion to reset the mandatory conference due to being indisposed with gout in his right ankle and fatigue from recent travel. He requests to postpone the conference until March 11, 2014. Additionally, the motion asks the respondents to provide the complainant's complete medical records pertaining to the case, as the complainant has a right to access these documents. Other relief is also sought.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    of 2

    P

    A
    G
    E


    1


    O
    F


    2


    -

    U
    R
    G
    E
    N
    T

    M
    O
    T
    I
    O
    N

    T
    O

    R
    E
    S
    E
    T

    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.


    P
    A
    G
    E


    2


    O
    F


    2


    -

    U
    R
    G
    E
    N
    T

    M
    O
    T
    I
    O
    N

    T
    O

    R
    E
    S
    E
    T

    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
    __________________________
    __________________________
    __________________________

    You might also like