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Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City

LEONILA MOLINA BIGUTE, ET

AL.,
Complainants,

-versus- NLRC-NCR Case No. 07-00529-

21

4TH DIMENSION MULTI-PURPOSE COOPERATIVE/

MARILES ELGARICO
Respondents.
X----------------------------------------------------------x

MOTION TO ADMIT THE ATTACHED POSITION PAPER

RESPONDENT 4th Dimension Multi-Purpose Cooperative (“4th

Dimension”), by the undersigned, to this Honorable Office, most
respectfully states:

1. The respondents were not able to receive the order requiring them
to submit Position Paper and it was only on 29 November 2021 when the
respondent Ms Mariles Elgarico went to the office of 4 th Dimension Multi
Purpose Cooperative that she learned that an order requiring them to
submit position paper was issued;

2. That the office of the Respondent 4th Dimension Multi Purpose

Cooperative has been closed since April 2020 due to the pandemic and all
employees has been in work from home arrangements;

3. That the respondent cooperative has made efforts and in the

process of possible settlement with the Complainants;

4. Be that as it may, the respondents, through the undersigned pray

for the admission of their position paper attached in this motion;

5. This motion is not intended to delay the proceedings of this case

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but only because of the foregoing reasons.

PRAYER

WHEREFORE, premises considered, and in the interest of

justice, it is most respectfully prayed that the instant motion be granted
and the Respondents be allowed to submit its Position Paper.

For Quezon City, 05 December 2021.

MARICEL PADIERNOS
General Manager
th
4 Dimension Multi-Purpose Cooperative
#27-B Benitez Street, Brgy Horseshoe
Village Cubao, Quezon City

Copy Furnished:

LEONILA MOLINA BIGUTE, ET

AL.,
Complainants
101 Samson St., Brgy Baritan
Malabon City, Metro Manila

Explanation

A copy of the foregoing motion and attached Position Paper is being

sent through registered private courier considering the distance and lack of
personnel during pandemic.

Maricel Padiernos
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