Model essay on labor dispute application (general 10)

Recommended topic: Application for Labor Dispute.

Model clause of labor dispute application 1 Complainant: xx Building, xx City,No. xx Road, xx District, XX City, postal code: XXXXXXXX, telephone number: XXXXXXXX.

Legal representative: xxx, female, xx years old, xxxx. Authorized Agent: xxx, lawyer of xx Law Firm in xx City.

Defendant: xxx, male, aged, employee of xx Building, xx City, living in xx Street, xx District, xx City.

Arbitration request:

1. Ask the judge and the defendant to compensate the training fee of 3,000 yuan;

2. Request for ruling that the defendant continues to perform the labor contract.

Facts and reasons:

The complainant is a foreign-invested enterprise engaged in hotel business. In March 20xx, the defendant entered the building through open recruitment and received pre-job training. In May 20xx, the defendant signed a five-year labor contract with the complainant. In July, 20xx, the defendant submitted his resignation to the complainant on the pretext that he suddenly left his job and "jumped ship" to xx Hotel without going through the formalities for dissolving the labor contract as required, and signed a labor contract with him. After that, the complainant sent several notices to the defendant urging him to return to his post, but the defendant never continued to perform the labor contract. The labor contract signed by the plaintiff and the defendant is legal and valid, which is a sincere expression of both parties on the premise of voluntariness and should be protected by law. The contract stipulates: "Either party must notify the other party in writing one month in advance before going through the formalities of dissolving the contract." The defendant left the building without fulfilling the above procedures, which violated the labor contract. The contract also stipulates: "If Party A terminates the labor contract in violation of regulations, it shall immediately correct it after confirmation by the arbitration institution, continue to perform the contract, and compensate Party B for the economic losses caused thereby. If Party B violates the regulations and leaves without authorization before the expiration of the contract, it shall compensate Party A for the training fee of 3,000 yuan. " Therefore, the defendant shall bear the liability for breach of contract agreed in the contract.

In view of the fact that the defendant's behavior seriously violated the labor contract between the defendant and the complainant, it affected the complainant's management business and adversely affected the complainant's management business. As there is no hope of reconciliation between the two parties, according to Article 3 1 of the Labor Law of People's Republic of China (PRC) and Article 8 of the Measures for the Implementation of Labor Management in Sino-foreign Joint Ventures, the arbitration institution is specially invited to find out the situation and uphold justice according to law.

Evidence and source, witness's name and address: The defendant's breach of contract is proved by the following evidence:

1. The labor contract signed by the defendant and the plaintiff in May 20xx shows the labor relationship established between the defendant and the plaintiff.

2. Witness Wang xx, male, employee of xx Hotel, living in Room 302, No.61xx New Village, xx District, xx City. He can prove the fact that the defendant established labor relations with xx Hotel.

I am here to convey

Xxx arbitration commission

Complainant: xx Building, xx City (official seal)

Legal representative: xxx (seal) Authorized agent: xxx (seal)

20xx year x month x day

Attachment: 1 1 labor contract;

2. 1 witness statement;

3. 1 complaint.

Labor dispute application model essay 2 Respondent: Company address:

Legal Representative: Tel:

Arbitration request:

The respondent was sentenced to pay the applicant a one-time economic compensation of 4,320 yuan for the illegal termination of the labor contract.

What happened:

The applicant believes that:

Because the respondent violated the law and violated the legal rights and interests of the applicant, and his attitude was tough, which seriously undermined the harmonious development of labor relations, which triggered the occurrence of this labor dispute case and should bear corresponding legal responsibilities. According to Article 5 of the Constitution of People's Republic of China (PRC), "the state maintains the unity and dignity of the socialist legal system; All violations of the Constitution and laws must be investigated. " In order to defend the unity and dignity of the national legal system and safeguard the legitimate rights and interests of the applicant, according to the Law of People's Republic of China (PRC) on Mediation and Arbitration of Labor Disputes, the applicant hereby applies to the Labor Dispute Arbitration Committee of Daojiao Town, Dongguan City for labor arbitration. Please ask the Arbitration Commission to find out the facts and make a fair treatment according to law.

I am here to convey

Dongguan Daojiao Town Labor Dispute Arbitration Committee

Applicant:

Applicant: Zou xxx, female, 198X, born in March, Han nationality, ID number: xxxx, household registration address:. Contact telephone number:

Respondent: Dongguan Jia xxx Mould Cup Factory; Company Address: Road side of Dalingya Village Center, Daojiao Town, Dongguan City.

Legal representative: Zhang xxx. Tel: xxx.

Arbitration request:

1); The respondent was judged to pay the applicant 2 160.4 yuan (fixed salary 20xx+ piece rate 160.4 yuan) and 25% economic compensation 540 yuan (2 160 yuan× 25%) in one lump sum, totaling 2,700 yuan.

2); The respondent was sentenced to pay the applicant a one-time economic compensation of 4320 yuan for the illegal termination of the labor contract.

3); It was judged that the respondent paid the applicant 6,000 yuan in one lump sum (20xx1February 8 to 20xx March 3 1 day, ***3 months 13 days) for failing to sign a written labor contract.

The total amount of the above three requests is 13020.4 yuan.

What happened:

On 20xx 1 18 years 10 months 18 days, the applicant worked as a "merchandiser" in the respondent's office, and no labor contract was signed between the two parties when they joined the company. Both parties verbally agreed that the candidate's basic salary is 20xx yuan, plus piece-rate commission; The respondent shall pay the applicant last month's salary by bank transfer on the 30th of each month; On March 25th, 20xx, the respondent asked the applicant to write a resignation letter on the grounds that the applicant was incompetent, but the applicant refused, saying that others had no right to ask me to write a resignation letter unless he wanted to. Later, the respondent dispatched responsible persons at all levels to persuade the applicant to write a resignation letter, but it was fruitless. On March 30th, the respondent issued a "resignation letter", forcibly dissolving the labor relationship with the applicant, but on the grounds of financial business trip. However, the respondent failed to fulfill the agreed obligations, only paid the February salary to the applicant, and deliberately defaulted on the March salary. After that, the applicant repeatedly asked the respondent to pay the salary, to no avail. On April 28th, 20xx, the applicant and the respondent conducted mediation in Daojiao Town Labor Bureau, but the mediation failed. The average monthly salary of the applicant before leaving the company is 2 160 yuan.

The applicant believes that:

1, according to Article 3 and Article 50 of the Labor Law of People's Republic of China (PRC), the applicant, as a laborer, has the right to receive remuneration after providing labor. It is the legal obligation of the employer to pay the labor remuneration to the applicant in time and in full. In this case, the respondent arranged for the applicant to work, but failed to pay the due labor remuneration in time after dismissing the applicant, which violated the provisions of Article 13 of the Regulations on Wage Payment in Guangdong Province that "if the employer terminates or terminates the labor relationship with the employee according to law, the employee's salary shall be settled on the date of termination or dissolution". Therefore, the respondent shall pay the unpaid salary of 2 160 yuan to the applicant. 540 yuan (2 160 yuan× 25%) who is 25% in arrears of wages shall also be paid in accordance with the provisions of Article 3 of the Measures for Economic Compensation for Violation and Termination of Labor Contracts.

2. The respondent forcibly dismissed the applicant on the grounds that the applicant was "incompetent", without any basis, and it was illegal to terminate the labor contract. According to Articles 47, 48 and 87 of the Labor Contract Law of People's Republic of China (PRC); According to Article 27 of the Regulations for the Implementation of the Labor Contract Law of the People's Republic of China, the monthly salary of economic compensation stipulated in Article 47 of the Labor Contract Law shall be calculated according to the wages due to the workers, including hourly wages or piece-rate wages and monetary income such as bonuses, allowances and subsidies. , the respondent shall double the economic compensation of 4320 yuan to the applicant (calculation method: average monthly salary of 2 160 yuan× 65438 yuan).

3. After establishing labor relations with the applicant, the respondent fails to sign a written labor contract with the applicant according to law. According to Articles 10 and 82 of the Labor Contract Law of People's Republic of China (PRC), the respondent shall pay the applicant twice from March 20th, 20xx 12 18 to March 3rd, 20xx1.

Because the respondent violated the law and violated the legal rights and interests of the applicant, and his attitude was tough, which seriously undermined the harmonious development of labor relations, which triggered the occurrence of this labor dispute case and should bear corresponding legal responsibilities. According to Article 5 of the Constitution of People's Republic of China (PRC), "the state maintains the unity and dignity of the socialist legal system; All violations of the Constitution and laws must be investigated. " In order to defend the unity and dignity of the national legal system and safeguard the legitimate rights and interests of the applicant, according to the Law of People's Republic of China (PRC) on Mediation and Arbitration of Labor Disputes, the applicant hereby applies to the Labor Dispute Arbitration Committee of Daojiao Town, Dongguan City for labor arbitration. Please ask the Arbitration Commission to find out the facts and make a fair treatment according to law.

I am here to convey

Dongguan Daojiao Town Labor Dispute Arbitration Committee

Applicant: xxxx

Xx，xx，XX，XX

Applicant: _ _ _ _ _ _ _ _ _ _ _ _ _ Trading Company.

Address:No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Legal Representative: _ _ _ _ _ _, general manager.

Respondent: _ _ _ _ _ _ limited liability company.

Address:No. _ _ _ _ _ _ _.

Legal Representative: _ _ _ _ _ _, chairman of the board.

The applicant has submitted an arbitration application to you for the dispute over the purchase and sale contract with the respondent, requesting the respondent to make an arbitration award and return the outstanding payment to the applicant. According to the recent information obtained by the applicant, it is confirmed that the respondent has shown a trend of selling vehicles and transferring assets in an attempt to evade debts due to long-term poor management and serious losses.

In order to ensure that the economic interests of the applicant can be implemented smoothly after the arbitration award, according to the relevant provisions of the Civil Procedure Law and the Arbitration Law, we now apply to you: request the respondent to take arbitration preservation measures, freeze the bank deposit of 800,000 yuan of the respondent, or seal up or detain other property of the respondent with corresponding value. If the economic loss of the respondent is caused by improper arbitration preservation measures, the applicant is willing to bear all the liability for compensation.

I am here to convey

_ _ _ _ _ _ Arbitration Commission

Applicant: _ _ _ _ _ _ _ Trading Company

Legal Representative: Zhao.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Model labor dispute application form Article 3 Applicant's name: _ _ Gender: _ _ Date of birth: _ _ _ _ _ _ Occupation: _ _ Work unit: _ _ Company (when applying for arbitration, no company writes its original company), and ID number: _ _ _ _ _ _ _.

Address and telephone number. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Respondent: _ _ _ _ _ _ _ company (full name of the company shall be stated)

Domicile and telephone number:No. _ _ _ _ _ Building, Liuzhou City Name of legal representative or principal responsible person: _ _ Position: _ _ Requirements:

1, and the respondent is judged to pay the applicant the economic compensation of _ _ _ _ _ _ yuan for the termination of the labor contract.

2. It is ruled that the respondent has paid _ _ _ _ _ _ _ _ _ _ _ _ to the applicant.

Overtime pay for legal holidays during the day is RMB _ _ _.

3. ruling; ruling ....................

Facts and reasons:

The applicant entered the office of the respondent on _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. The period of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. The applicant requests the Arbitration Commission to award the respondent to pay the economic compensation and overtime pay of RMB _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

Applicant _ _ (signature)

_ _ _ _ _ _ _ _ _ _ _ _ _

Article 4 of the Model applies to labor disputes: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Respondent: _ _ _ _ _ _ _ _ _ _ _ _ _ _ Guangzhou Sporting Goods Co., Ltd., whose domicile is _ _ _ _ _ _ _ _ _ _ _ _ _ _ Baiyun District, Guangzhou. Postal code: _ _ _ _ _ _ _ _ _ _ _ 510440

Legal Representative: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. Tel: _ _ _ _ _ _ _ _ _.

Arbitration request: _ _ _ _ _ _ _ _ _ _ _ _

1. Request a ruling to dissolve the labor contract relationship between the respondent and the applicant;

2. Request the judgment that the Respondent shall pay the applicant six months' economic compensation 10467.4 yuan;

3. Request for ruling that the respondent pays social insurance premiums for the applicant year by year.

Facts and reasons: _ _ _ _ _ _ _ _ _ _ _ _

In, the applicant applied to Guangzhou Baiyun Sportswear Co., Ltd. (hereinafter referred to as Baiyun Company), whose main job was to operate flat cars and special cars. /kloc-in October, Baiyun Company proposed that its affiliated company Guangzhou Sporting Goods Co., Ltd. (the respondent) continue to perform the labor contract. Except for the change of the name of the employer, the contents of other labor contracts, including labor posts, labor remuneration and labor place, remain unchanged. During the performance of the labor contract, the respondent repeatedly violated the labor rights and interests of the applicant. 1 month, because the respondent deducted several thousand yuan from the applicant's basic salary, the applicant and others raised strong objections, so the respondent reissued 65,438 yuan+0,000 yuan to the applicant, which was sloppy. On, the respondent signed a labor contract with the applicant, and the term of the labor contract was 1 year. Since entering the factory, the applicant has worked hard, worked overtime and devoted his youth, but the respondent has never paid attention to the applicant's future social security, evaded laws and regulations, and failed to pay social insurance benefits for the applicant, which seriously damaged the applicant's labor rights and interests. From 1 month, the respondent unilaterally changed the working place and moved the main production equipment from Guangzhou to Heyuan. So far, the relocation has been basically completed, and the complainant is required to follow up. The complainant repeatedly asked the respondent to pay social insurance, but was rejected. In order to protect their own rights and interests, we hereby propose to terminate the labor contract, and at the same time require the respondent to pay the corresponding economic compensation and pay the social insurance premium. The above request was supported by the Arbitration Commission.

I am here to convey

Guangzhou Labor Arbitration Commission

Applicant: _ _ _ _ _ _ _ _ _ _ _ _

date month year

Model text of labor dispute application 5 According to the provisions of Article 28 of the Labor Dispute Mediation Law of People's Republic of China (PRC) (omitted) and Article 29 of the Rules for Handling Labor and Personnel Disputes, the applicant shall submit a written application, which shall include the following contents:

(a) the name, sex, age, occupation, work unit, domicile, mailing address and telephone number of the laborer, the name, domicile, mailing address and telephone number of the employer, and the name and position of the legal representative or principal responsible person;

(2) the request and the facts and reasons on which it is based;

(3) Evidence and its sources, names and residences of witnesses.

If it is really difficult to write an application, you can apply orally, which will be recorded by the _ _ _ Committee and confirmed by the applicant's signature or seal.

If the written application materials of the applicant are complete, the Committee shall issue a receipt.

If the application is not standardized or the materials are incomplete, the Committee shall inform the applicant of all the materials that need to be corrected on the spot or within five days. If the applicant supplements all the materials as required, the Committee shall issue a receipt.

According to the relevant provisions of laws and regulations, the application for labor dispute shall include the following contents:

(1) The name, sex, age, occupation, work unit and domicile of the laborer, the name and domicile of the employer, and the name and position of the legal representative or principal responsible person;

(2) the request and the facts and reasons on which it is based;

(3) Evidence and its sources, names and residences of witnesses.

Applicant: Yang X, male, Han nationality, born on April 5, 20xx, living atNo. 19, Luyang District Road, Hefei City.

Respondent: Hefei Co., Ltd. Address:No. Industrial Park Road, Hefei XX Development Zone.

Legal Representative: Chairman of the board of directors of this company. Tel:. Arbitration request:

1. ordered the respondent to pay the applicant compensation for the termination of the labor contract (12,500 yuan/month x 10.5 month) ×2 times = 262,500 yuan;

2. Order the respondent to pay the applicant a bonus of 20,000 yuan in the first and second quarters of 20xx;

Three. Ordered the respondent to pay the annual leave salary of the applicant (12500÷2 1.75) yuan/day ×(5 days/year× 3 years) days × 3 times =25862 yuan;

4. Ordering the respondent to handle social security transfer, unemployment and other procedures for the applicant.

Facts and reasons:

Apply to join the respondent's company for financial work in June, be transferred to the company's sales management department as the deputy manager in May, be the commercial director in June, and be the deputy manager of the marketing department after July. The salary of the applicant is monthly basic salary+quarterly bonus+year-end bonus. The applicant's monthly basic salary of 20xx is 5,000 yuan, the bonus of the fourth quarter is 40,000 yuan, the year-end bonus is 50,000 yuan, and the average monthly salary is12,500 yuan. In June, 20xx, the applicant asked the respondent for leave because of something, and obtained the consent of the respondent. During the leave period, the applicant still audited the business statements in strict accordance with the requirements of the respondent company. Since the paid annual leave system was implemented in 20xx65438+1 October1day, the respondent has not arranged annual leave for the applicant, nor has it paid the applicant the salary for not taking annual leave. On July 23rd, 20xx, the respondent inexplicably published an announcement in Hefei Evening News, claiming that the applicant would go to work in the company during the leave period, and terminated the labor contract with the respondent. The applicant talked to the respondent many times, but the respondent didn't explain it. In addition, the respondent deducted the applicant's bonus of RMB 20,000.00 in the first quarter 1 and the second quarter of 20xx.

The applicant believes that the respondent shall pay compensation if it terminates the labor contract illegally; The respondent shall pay the paid annual leave salary to the applicant; The respondent shall pay the bonus of the applicant in the first and second quarters. In order to safeguard the legitimate rights and interests of the applicant, the applicant hereby applies to your Committee for labor arbitration, and earnestly asks the applicant to feel the same way!

I am here to convey

Labor dispute arbitration commission

Applicant:

Xx，xx，XX，XX

Application for labor dispute mode Article 7 Applicant: xxx Automobile Industry Parts Co., Ltd., domicile: No.5 Gutian Road 17, Qiaokou District, xxx City (No.0/02, 3rd Floor, Sanxin Material Industry Incubator), postal code: xxx, telephone number: xxx.

Respondent: Wang Bingnan, female, Han nationality, born on April 29th, 1969, living in 3-14 Building, Bihu Community, xxx, with postal code xxx and telephone number xxxxxxx.

Application items:

1. Cancel the arbitration award of xx old arbitration word [20xx]No. 198.

2. The litigation costs of this case shall be borne by the respondent.

Facts and reasons:

1. The facts on which the arbitration is based are unclear.

The applicant began to undertake the comprehensive cleaning service project of xx on July 1 day, 20xx. After undertaking the project, the applicant signed a labor subcontracting contract with the third party xxx on the same day to subcontract the labor work in the project to the third party. The respondent is a worker employed by a third party. It is wrong for xx Arbitration Commission to conclude that there is a labor relationship between the applicant and the respondent without ascertaining the above facts.

2. The legal application of the arbitral award is wrong.

On August 24th, 20xx, the respondent was employed as a cleaner in a third-party company, and on March 4th, 20xx, the respondent terminated the labor relationship with the third-party company for some reason. The respondent applied to the 20xx Labor Dispute Arbitration Committee for labor arbitration on 20xx 10 +065438. According to the provisions of relevant laws, its arbitration claim has obviously exceeded the arbitration period and should be rejected according to law. However, in the absence of any legal basis, the xx Arbitration Commission decided that the respondent's request was not overdue and supported, which did not comply with the law.

3. The arbitration procedure is illegal.

Before the arbitration hearing, the applicant submitted an application for adding a third person to xxx Labor Dispute Arbitration Committee, and the Arbitration Committee agreed to add a third person. The third person also participated in the trial and debate in accordance with the law, and signed the trial record for confirmation. However, in the final ruling, there was no agreement to add a third party, no ruling on the third party, and no reasons were given. This behavior of the Arbitration Commission is a serious violation of the Arbitration Procedure Law.

To sum up, the Labor Dispute Arbitration Commission found that the facts were unclear, the application of the law was wrong, and the legal procedures were violated, and the arbitration award made violated the legitimate rights and interests of the applicant. Therefore, according to the provisions of Article 49 of the Labor Dispute Mediation and Arbitration Law, a lawsuit is brought to your hospital, and your hospital is willing to make a judgment as requested.

I am here to convey

Salute!

Applicant:

20xx August 9th

Article 8 of the model application for labor dispute: Counterapplicant: Mould Co., Ltd.

Legal representative: manager.

Respondent: name and contact information.

Counterclaim:

It is requested to order the Respondent to compensate the Respondent for the economic loss of 8,449.39 yuan caused by serious dereliction of duty.

Facts and reasons:

The respondent went to work for the respondent on March 20th, 20xx, and worked as a locksmith.

On June 7th, 20xx, the respondent did not follow the workflow when completing the molding work of FAW MV3-53 1038 1, resulting in the dislocation of the upper and lower molds, and the whole set of molds of MV3-53 1038 1 was scrapped, resulting in direct economic losses.4089.000000000105

On July 8th, 20xx, the respondent resigned. The respondent did not make any compensation for the losses caused to the respondent. Now the applicant has filed a counterclaim according to law, please make a ruling according to law.

I am here to convey

Yantai labor personnel dispute arbitration commission

Counterapplicant:

Date of application:

Article 9 of the model application for labor dispute: _ _ _ _ _ _ _ _ _, male, Han nationality, born on _ _ _ _ _ _ _ _ _ _ _ _.

Respondent: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

Application requirements:

1. Request you to order the respondent to pay the economic compensation and compensation to the applicant for seven months;

2. Request you to order the respondent to pay the applicant's medical subsidy for 9 months (subject to the final labor ability appraisal);

3. Ask you to order the respondent to pay the applicant 12 months double salary without signing an open-ended labor contract;

4. Ask your committee to order the defendant to pay the applicant three and a half months' salary;

5. Request your committee to order the respondent to pay the applicant _ _ _ _ _ and go through the relevant formalities;

6. Ask your committee to order that the defendant bear the medical expenses of the applicant.

Facts and reasons:

In September of _ _ _ _, the applicant went to work for the respondent as an external foreman with a monthly salary of 3,950 yuan. On September 8, _ _ _ _ _ _ _, the applicant was hospitalized for cerebral hemorrhage; _ _ _ _ _ _ _ year 65438+1October 65438+August, the applicant was discharged from the hospital and went home for further treatment. Because the applicant is seriously ill, the respondent unilaterally terminates the labor contract with the applicant. During the existence of the labor relationship, the respondent has never signed a formal written labor contract with the applicant, nor has he paid various social _ _ _ _ _ to the applicant, so he should bear various responsibilities.

Second, because the applicant suffers from a serious illness, he can't engage in his original job, nor can he engage in other jobs arranged by the respondent. According to Article 6 of the Measures for Economic Compensation for Violation and Termination of Labor Contract, the respondent shall pay the applicant nine months' salary as medical aid (subject to the final labor ability appraisal).

_____

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Article 10 of the labor dispute application form: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Defendant: _ _ _ _ _ _ _ Address: _ _ _ _ _ _ _

Legal representative: _ _ _ _ _ Person in charge: _ _ _ _ _ _ Tel: _ _ _ _ _ _

Defendant: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Legal Representative: _ _ _ _ _ Tel: _ _ _ _ _ _ _

Matters applying for arbitration:

1. Request the Arbitration Commission to award the respondent a labor economic compensation of 5 100 yuan according to law.

2. Request the Arbitration Commission to award the respondent to pay the social insurance premium of the applicant _ _ _ _ _ _ _ _ _ _ _ _ _ _.

3. Require the two respondents to pay overtime pay in RMB.

Facts and reasons:

In February 2002, the applicant was sent to work in the body factory by Shiyan Labor Service Company. The respondent's behavior seriously violated the provisions of the Labor Contract Law and failed to pay economic compensation according to law. In order to safeguard the legitimate rights and interests of the applicant, please ask the arbitration commission to make an award according to law.

I am here to convey

Labor arbitration Committee

Applicant: _ _ _ _ _ _