Enrico Properties, AG, a German corporation engaged in the business of manufacturing, selling

and exporting elevators and other building equipment intends to establish a branch office in
the Philippines and build its manufacturing plant at PEZA, Canlubang, Calamba, Laguna. It also
intends to hire expats from Germany and Filipino who have at least worked in a related field for
at least 2 years.

After the registration of the Corporation, the Board of Directors started hiring officers and
employees. It engaged the services of Roben as the General Manager of the Philippines branch
and Jihan as the Supervisor for Operations and executed an Employment Contracts with the 2
for a term of three(3) years. After the lapse of 1 year, the branch terminated their employment.

As it's retained lawyer, prepare the following:

1. Notice of Termination

2. Affidavit of Waiver and Quitclaim

Assuming that Roben and Jihan filed a labor complaint with the labor arbiter for illegal dismissal
and claimed for the payment of their salaries for the unexpired portion of ttheir employment
contracts.

3. Prepare the Position Paper of the branch office to be filed with the Labor Arbiter

4. Prepare Notice and Memorandum of Appeal with the NLRC ( assuming that the Labor Arbiter
decided against the branch).