Republic of the Philippines
Department of Labor and Employment
NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. ___
________ City
(NAME OF HON. LABOR ARBITER)
NAME OF COMPLAINANT, NLRC CASE NO. _____________
Complainant,
-versus-
NAME OF RESPONDENT,
Respondent.
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MOTION TO DISMISS
RESPONDENT, through undersigned counsel, most respectfully submits this Motion and states, THAT:
1. The parties in the instant case have agreed to amicably and fully settle all the issues affecting the aforementioned case and complainant has executed Release Waiver and Quitclaim, duly attested by two witnesses. Copies of Quitclaim, Waiver and Release is hereto attached as Annex “A”;
2. Pursuant to the above Quitclaim, Waiver and Release, respondent is hereby submitting the instant Motion to Dismiss the aforementioned case from this Honorable Office and dismiss any and all existing claims arising therefrom.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this Honorable Commission to DISMISS the instant case RAB _______________, and any and all claims arising therefrom with prejudice and to drop the said case from the business calendar of the case.
Other reliefs, just and equitable under the premises, are likewise prayed for.
(Date), (Place), Philippines.
LAWYER DETAILS
Copy furnished:
COMPLAINANT
NOTICE
The Hon. Clerk of NLRC-RAB________
___________ City
GREETINGS!
Please be advised that the foregoing Motion is submitted for the due consideration and approval of this Honorable Office immediately upon receipt hereof sans any oral argument on the part of the undersigned.
LAWYER
