How to write the indictment for arrears of wages for migrant workers?

There are four contents in the indictment of wage arrears for migrant workers:

1, basic information of employers and workers;

2. The request and the facts and reasons on which it is based;

3, evidence and evidence sources, witness's name and domicile. The employer's arrears of wages for migrant workers is a labor dispute, and before applying for litigation through arbitration procedures, it should be subject to labor arbitration;

4, the prosecution unit and company seal, write clearly the date.

How to write the complaint of arrears of wages for migrant workers

Prosecuting unit: (full name): _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Nature of enterprise: collective

Scope: industrial and civil buildings. Industrial and civil buildings,

Working capital: _ _ _ ten thousand yuan.

When and what department approved the opening? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Bank of deposit: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

Account number: _ _ _ _ _ _ _ _ _ _ _

Name of Legal Representative: _ _ _ _ _ _ Title: _ _ _ _ _ _

Defendant's unit (full name): _ _ _ _ _ City Staff Education and Training Center

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

Subject matter: Disputes over arrears of project funds in the Construction and Installation Project Contract.

Facts and reasons:

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

The contracting method is "the form of bidding negotiation and material contracting".

The contract amount is _ _ _ _ yuan.

The commencement date is _ _ _ _ _ _ _ _ _ _. The completion date is _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

After the signing of the contract, Party B delivered the equipment and tools to the site on time, but Party A failed to negotiate with the relevant units due to reasons such as site and drawings. Until _ _ _ _ _ _ _ _ years ago.

Within one hundred and seventy-seven days, it exceeds _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Although Party A has paid RMB for lost time, there is still RMB left.

After the installation of two dormitory buildings was completed, it was on _ _ _ _ _ _ _ _ _ _ _

The teaching building project was completed on _ _ _ _ _ _ _ _ _ _ _.

All three buildings were accepted and delivered to the defendant by the _ _ _ _ _ _ Municipal Construction Engineering Quality Supervision Station.

The project statement shall be submitted to _ _ _ _ _ _ _ _ Construction Bank for calibration after being examined and approved by both parties, and there is no dispute between the two parties.

Party A should settle the project payment with Party B according to the contract, but Party A still owes Party B the project payment of 265,438 yuan+0,793 yuan and 06 yuan.

From, Party A requires Party B to delay the construction of its spare parts.

After many negotiations, Party B reached an agreement to build a garage, boiler room, dam wall and other zero construction projects for Party A..

However, the labor rent of RMB has not been settled with Party B so far.

Due to Party A's repeated arrears in the project payment to Party B, the wages of Party B's workers could not be paid for a long time, and they were forced to leave Party A's construction site at the end of _ _ _ _.

In order to recover the project payment owed by Party A, Party B organized a special person to negotiate with Party A for many times.

At first, Party A delayed the project on the grounds of incomplete engineering data, and Party B had to copy all his own data to Party A. ..

Later, on the grounds that the price difference of building materials was unreasonable, Party A refused to pay the project funds owed by the original dormitory and teaching building, and by extension, refused to review the settlement of all zero construction projects constructed by Party B in the later period.

To sum up, Party A violated the contract, unilaterally overturned the relevant clauses stipulated in the contract, and unreasonably defaulted on the project payment to Party B, causing great economic losses to Party B. ..

The General Principles of the Civil Law of People's Republic of China (PRC) stipulates that if the contractor fails to perform his due responsibilities in accordance with the contract, the completion date shall be postponed and the actual losses suffered by the contractor shall be compensated; Failing to allocate the project funds according to the provisions of the contract; According to the relevant provisions of the bank's overdue payment method or the "project price settlement method".

Litigation request:

Order Party A to pay the project price and compensate Party B for economic losses;

(a) to pay off the arrears of dormitory and teaching building _ _ _ _ yuan;

(2) Cost settlement of spare parts project: RMB _ _ _ _ _ _ _ _

(III) Compensation for economic losses of Party B: the overdue fine from _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

The above three items add up to * * * _ _ _ _ yuan.

I am here to convey

_ _ _ _ District People's Court

Prosecuting unit: _ _ _ County Construction Engineering Company

_ _ _ _ _ _ _ Company (Seal)

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

Legal basis: Article 12 1 of the Civil Procedure Law of People's Republic of China (PRC).

The complaint shall contain the following items:

(1) The name, sex, age, nationality, occupation, work unit, domicile and contact information of the plaintiff, the name and domicile of the legal person or other organization, and the name, position and contact information of the legal representative or principal responsible person;

(2) Information such as the name, gender, work unit and domicile of the defendant, and information such as the name and domicile of the legal person or other organization;

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

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