EXPEDIENTE NÚMERO:_________________

EXTENSION OF DEMAND
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H. FEDERAL COURT OF ADMINISTRATIVE JUSTICE
IN THE STATE OF XXXX
PRESENT

LIC. XXXX XXXX XXXX XXXXX, legal representative of the company named
XXXXX XXX XXXXX XXXXX, S.A. DE C.V., which personality I have accredited and
recognized by this H. Authority, reiterating the domicile indicated to receive
appointments and notifications in the nullity action that gave rise to the above-
mentioned file, as well as to receive documents, the one located at Avenida XXXXXXX,
number XXXXXX, Colonia XXXXXXXX de XXXXXXXX, XXXXXXXX, Có. I also
authorize for purposes of hearing and receiving all kinds of appointments and
notifications, review the file, take notes, make copies, photographs, scan and collect all
kinds of documents indistinctly to CC. LIC. _________________________________, before you
with due respect, I appear and expose:

Por medio del presente escrito, y en desahogo a la vista que se le dio a mi

poderdante mediante auto de fecha 03 de noviembre del 2016 y publicado en el
Boletín Jurisdiccional con fecha 23 de Noviembre de 2016, estando dentro del término
concedido, vengo a AMPLIAR DEMANDA DE NULIDAD, lo cual se hace con
fundamento en lo dispuesto en la fracción IV of Article 17 of the Federal Law of
Administrative Contentious Procedure, since with the answer to the complaint, the
respondent authority introduces as a novel issue for my client, that the file
XXX/XXXX/XXXXXXX is unrelated to the resolution issued in the file XXX.
1S.XXX.XXXXX.2015, a statement with which we do not agree, and which affects the
failure to comply with the requirements and elements of the administrative acts
specifically as provided in sections II, III, V, VII, VIII; IX, XII and XVI of the Federal Law of
Administrative Procedure.

The basis of the present extension consists of the fact that when answering the
complaint, the authority states that what was said in fact one of the nullity complaint is
false, referring to the fact that my principal cites the extraordinary inspection order
number XX/XXX/2015, however, the defendant answers that the order issued in the
file XXXX.1S.XXXX.XXXX.XXXX.2015 is the order of COMPROBATION
XXX/XXXXXX/2015. In response to the foregoing, it is stated that the administrative
authority ACTS WITH DOLE AND FALSENESS, since with its answer it intends to
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dissociate and/or dissociate and/or make the EXTRAORDINARY inspection order
number XXX/XXXX/2015 alien and strange. However, this is incorrect, as will be
explained in the present document.

This H. The Chamber will be able to corroborate that I am right and for this
purpose I proceed to quote a part of the resolution dated July 04, 2016, where the
defendant CITES THE INSPECTION ORDER THAT IN ITS RESPONSE TO THE SUIT IT
PRETENDS TO DISKNOW, I proceed to quote and point out that this appears on page 4
of 15 of the resolution. N DE DE DE DEMAND PREEMTS TO DISCLAIM, I proceed to
quote and point out that this appears on page 4 of 15 of the resolution, proceeding in
this act to quote verbatim:

"In relation to the complaints pointed out by the appellant, once they have been analyzed,
this resolution authority considers that they are unfounded, by virtue of the fact that from
the analysis of the proceedings of file no. XXXXXXXXXX, it is noted that in what the legal
representative refers in her first point of grievance, this federal authority rejects such
argument, because although Article 16 of the Federal Law of Administrative Procedures in its
section VI states that the Federal Public Administration must refrain from requesting
documents that are in the file that is being processed, it is clarified to the company that such
inspection of safety and hygiene measures is scheduled since in the inspection
XXX/XXXXX/2015 of safety and hygiene it did not solve such violations. being processed, it is
clarified to the company that said inspection of verification of safety and hygiene measures
is scheduled since in the XXX/XXXXX/2015 inspection of safety and hygiene it did not
solve said violations, therefore this labor authority schedules said inspection of verification
of measures....." .....
"as is reflected in the inspection report number XX/XXX/2015, so it is wrong to state that the
company has already provided such evidence, when the logical thing is that if it had
provided such evidence in the health and safety inspection with number XX/XXXX/2015, no
inspection would be scheduled".gico is that if it had provided them in the health and safety
inspection with number XX/XXXX/2015, no inspection for the verification of health and
safety measures would be scheduled."

Note this H. Chamber as if the elements of the administrative act are not
complied with to the detriment of the rights that I represent, due to the fact that the
imposition of the sanctions contained in the resolution issued in the file
XX.1S.XX.XXX/2015 that my client challenged by means of a nullity action DO HAVE A
DIRECT RELATIONSHIP WITH THE EXTRAORDINARY INSPECTION ORDER
XX/XXXXX/2015, and it is a violation of the PROCEDURAL rights that I represent, that
the authority considers them as alien and/or strange to the resolution where it imposed
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the fines, given that prior to the verification order, my client exercised the right granted
to it by Article 68 of the Mexican Constitution. the right granted by article 68 of the
Federal Law of Administrative Procedure, and presented the documentary evidences
that solved the requirements that were applicable to us, and those that were not
enforceable and/or applicable, even the defendant administrative authority was
informed of the inadmissibility of the summons, due to the fact that there was no
reason and legal basis for it.

In the aforementioned circumstances, being as it is that the order of

extraordinary inspection number XX/XXXXX/XXX, brought as a consequence the order
of verification, THE FIRST CANNOT BE DISCLAIMED, SINCE MY REPRESENTATIVE
SOLVED AND MANIFESTED what was convenient to his right, and of course the
defendant authority HAD THE OBLIGATION TO ATTEND TO SUCH CONSTANTIES, in
strict compliance with the elements of the administrative act, to consider otherwise is
tantamount to the authority acting with malice and bad faith, as well as to be pursuing
the administrative act, to consider that the authority is acting with fraud and bad
faith.To consider otherwise is equivalent to the authority acting with malice and bad
faith, as well as pursuing different purposes, since it seems that it is more interested
in finding a way to fine the companies than for them to comply with the labor
regulations, losing sight of the BALANCE between labor and the source of employment.

In this extension it is attributed to the Respondent that then its acts are not
precise as to the CIRCUMSTANCES OF TIME AND PLACE, since if on the one hand it
orders an extraordinary inspection from which a verification order will derive, it
CANNOT DISREGARD THE FIRST because it is equivalent to leaving the inspected party
in a state of defenselessness, in this case my respondent, because it means that the
evidence and proofs of compliance and manifestations that the Respondent has made
in this case, my client, are not precise.If on the one hand it orders an extraordinary
inspection that will result in a verification order, it CANNOT DISCLAIM THE FIRST
because it is equivalent to leaving the inspected party in a state of
defenselessness, in this case my client, because it means that the evidence and proof
of compliance and statements made by my client are not taken into account and it
illegally issues the verification order. (This statement is based on Section II of Article 3 of the
Federal Law of Administrative Procedure ).
 In this same order of ideas, from the answer to the complaint it is then clear
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that the acts attributed to the respondent authority, also do not comply with the
element of having as a purpose the public interest, since the interest of the inspection
visits ordered by the authorities, is in the sense that the employer complies with its
labor obligations.The interest of the inspection visits ordered by the authorities is in the
sense that the employer complies with its labor obligations, and if my client, within the
extraordinary inspection order, solved the inspection points, then, it made no sense
whatsoever to fine it, since the Law also contemplates warnings as measures of
constraint. It is therefore stated that if the authority, instead of enforcing its
determinations in a manner other than the excessive fines it imposes, then it is not
pursuing the public interest, since the labor authority must seek to achieve a balance
between workers and companies, in order to provide stability to sources of
employment, which is so much needed today.The labor authority should seek to
achieve a balance between workers and companies, in order to provide stability to the
sources of employment, which is so necessary today, since it is well known that the
situation in the state and in general in the country is worrisome in relation to the
generation of jobs.

In this same sense, it is argued that the Respondent is also challenged for
initiating the procedure by means of an extraordinary inspection order and then
initiating another verification procedure, WITHOUT TAKING INTO ACCOUNT THE
ACTIONS OF THE FIRST one.The fact that the file is NOT specifically referenced, because
it is equivalent to the fact that derived from an extraordinary order, other procedures
derived from the first one are opened, thus tending to the confusion of the acts and
files of the first one.This is because it is equivalent to opening other proceedings
derived from the first one, thus tending to confuse the administrative acts and files that
culminate with the imposition of fines, being that if they had been carried under the
same act and file number, even if verification orders were issued, it would be necessary
to take into account ALL THE ACTIONS THAT HAVE RELATIONSHIP WITH THE FIRST
ORDER.Therefore, they can be issued under the same file number and not under a
different number, thus avoiding confusion to the interested party (section VII article 3
of the Federal Law of Administrative Procedure). The above challenge is related to the
element that the act does not have to be fraudulent in its issuance, since the act has to
be issued(section XII), without any error with respect to the specific reference to the
identification of the file, documents or full name of the persons.
 Continuing with the present extension, it is also claimed that the authority
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when answering the lawsuit does not know the actions carried out and derived from
the extraordinary inspection order XXX/XXXX/2015, and my client exercised the right
of 5 days to solve the points of inspection, without receiving a response from the
authority, and we were not summoned for any non-compliance derived from the
aforementioned order.We did not receive any response from the authority, and we
were not summoned for any non-compliance derived from the aforementioned order,
however, the administrative authority decided to However, the administrative authority
decided to issue a verification order WITH A NUMBER OTHER THAN THE
EXTRAORDINARY ORDER, but nevertheless, in the resolution where it imposed the
fines, IT DOES REFER TO SUCH INSPECTION, which leads us to claim in the present
extension that the authority did not decide all the issues that were the reason for the
inspection.n that the authority did not decide all the points proposed as defense of my
client in attention to the order XXXXX/XXXXXXX/2015 (section XVI) Being issued
expressly deciding all the points proposed by the parties or established by law.

The above is stated, because my client opposed the inadmissibility of the

administrative summons in the file XXXX.1S.XXXX.XXXX.XX.2015, stating that my client
presented a written document formulating observations and resolving the points
observed in relation to the facts stated in the inspection report XXX/XXXXXX/2015,
which were sufficient to file the report without there having been a summons to
take measures against my client. However, the authority did not give an answer to
the above, therefore, the normative hypothesis that all the issues presented to the
authority were not resolved, which causes yet another violation of the rights of the
person I represent, is updated.

It was pointed out to the authority that in the summons to safety and hygiene
measures, the authority once again requested my client to accredit the points observed
in the inspection report, documents that were offered for the third time.
 Determination of fire risk
 Written format for the conduct of the simulation exercise
 Multifunctional brigades
 Certificates issued by Consultores Especializados en Prevención e
Investigación de Incendios S.A. de C.V. to employees.
 Fire Prevention and Fire Fighting Manual Use of Fire Extinguishers
 

Job risk analysis by position
Analysis of potential risks generated by machinery and equipment
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 Safety regulations for contractors
 Contract for the provision of integral conservation services
 Training program
 In-Store Certification 2015
 Proof of job skills
 Health and safety inspection protocol for self-service stores, distribution
centers, department stores and specialized stores.
 Industrial safety, occupational health and civil protection manual for retail
stores
 Industrial safety, occupational health and civil protection manual for retail
stores
 Quick guide in case of emergency
 Health effects of lowered temperatures manual
 Triptychs: order and cleanliness
 Loading technique
 National obesity and overweight campaign
 National vaccination campaign National campaign for the prevention of
diarrheal infections
 Risk prevention in stores
 Basic safety rules

However, the authority decided not to take into account the documents that
were provided as evidence by my client and with which the points observed in the
inspection report were solved, without providing a basis and reasoning, this omission
causes severe damage to my client, since it does not value the evidence in its entirety,
overriding Article 16 of the Federal Administrative Procedure Law which establishes that
it is the obligation of the authority to refrain from taking into account the documents
that were provided as evidence.This omission causes severe damage to my client, since
it does not evaluate the evidence in its totality, ignoring Article 16 of the Federal
Law of Administrative Procedure which establishes that it is the obligation of the
authority to abstain from requesting documents that are already in the file that is being
processed, and that this authority has the obligation of not requesting documents that
are already in the file that is being processed, and that this authority has the obligation
of not requesting documents that are already in the file that is already in the file that is
being processed. This authority has ignored this, so much so that once again they
issue another inspection order in which they once again verify the same points
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that have already been requested and solved, which leads us to think that the
purpose of public interest has been lost, because the objective is to sanction the public
interest.The objective is to sanction my client, forgetting the main objective of the
Ministry of Labor, which is to encourage workers and employers to work with dignity, to
promote the creation of new jobs and to promote a culture of prevention.

For the foregoing reasons, I respectfully request this authority:

SINGLE - To have my represented by extending the claim.

Villahermosa, Tabasco, November 18, 2016.

I OBJECT TO WHAT IS NECESSARY
_____________________________________
LIC. XXXX XXX XXXXX