How to write down the facts and reasons of labor arbitration in detail? 0? three

How to write the facts and reasons of labor arbitration: the company implements a 26-day and 8-hour working system; The basic salary of the company is 820 yuan/month, and overtime on normal working days and weekends is not uniform; 6 yuan/hour; The company does not allow employees to play overtime cards on normal working days and weekends; The company forged employee payroll; The company forces employees to work overtime; How to write these kinds of facts and reasons is1; How to write them is a fact and a skill-this is a professional problem; If the legal problem is not written in fact, it will surely win. None of this is true. You may not lose. 3. Winning the case = sufficient evidence+effective appeal+rich skills+judge's quality! ! Arbitration request: 1, requesting the respondent to pay the salary owed to the applicant of 5279.38+05 yuan; The economic compensation for unpaid wages of 25% for no reason is 13 19.79 yuan, * * *: 6598.94 yuan; 2. Request the respondent to pay economic compensation less than 200% of the total minimum wage 1 120 yuan; 3. Requesting the judgment that the respondent should pay the double salary of the applicant who did not sign the written labor contract from August 4, 2009 to June 7, 2009165438+1October 7, totaling 4,575.45 yuan; 4. Request for ruling that the respondent shall pay the applicant the economic compensation for dissolving the labor contract according to law: 1994.83 yuan; 5. Request for ruling that the respondent pays the applicant's high temperature subsidy: 300 yuan; 6. Request for ruling that the respondent shall pay the social insurance-related expenses of the applicant from August 2009 to February 20 10. If you can't pay, you will pay in cash. 7. Request the respondent to pay the daily lost time fee of RMB 4 1 yuan after the termination of the actual labor relationship, and bear all the expenses incurred by the applicant due to arbitration, including transportation expenses, data copying fees, etc. Facts and reasons: (including evidence and sources, names and addresses of witnesses, etc.). The applicant entered the respondent's company on August 3, 2009, but the respondent did not sign a written labor contract with the applicant at that time, but it was not until June 165438+ 10/8, 2009 that the written labor contract was signed with the applicant. During the working period, the respondent will pay the applicant the basic salary of 820 yuan every month and the overtime pay of 6 yuan/hour (usually the same as on weekends). The complained company implements the so-called 26-day and 8-hour working system, and going to work on Saturday is not overtime. The complained company is not allowed to play overtime cards outside the standard working hours. The respondent's company forced the applicant to work overtime. If the applicant does not work overtime, it will be regarded as absenteeism, and the applicant's basic salary will be deducted for each day of absenteeism. The defendant company forged the applicant's salary slip and said that if it didn't sign it, it wouldn't get the salary. The applicant has no choice but to sign. In view of various violations of laws and regulations in the respondent's company, the applicant was forced to serve the Notice of Dissolution of Labor Relations to the respondent's company on March 6, 20 10, demanding that the factual labor relations between the two parties be dissolved immediately, and demanding that the respondent pay the applicant's labor remuneration difference and corresponding economic compensation in full and on time according to law, totaling 14589.22 yuan, but the respondent refused to pay. In order to safeguard their legitimate rights and interests as workers, the applicant resorted to legal procedures against the respondent's violation of labor laws and regulations. 1. If the respondent pays the standard hourly wage and overtime wage below the minimum wage in Shenzhen, it shall pay the unpaid wages below the statutory standard. According to the second paragraph of Article 44 and Article 48 of the Labor Law of People's Republic of China (PRC), "The wages paid by the employer to the workers shall not be lower than the local minimum wage." The respondent shall pay the applicant the salary arrears of 5,279,438+05 yuan from August 3, 2009 to March 5, 2065. According to Article 58 of the Regulations on the Payment of Employees' Wages in Shenzhen, the applicant shall be paid an economic compensation of 5279.15 * 25% =1319.79 yuan for not paying 25% of the total wages without reason. According to Article 57 of the Regulations on the Payment of Employees' Wages in Shenzhen, 200% (900–820) * 7 * 2 =1120 yuan of the total minimum wage shall be paid to the applicant; Two, the respondent fails to sign a labor contract with the applicant within the statutory time, it shall pay twice the salary according to law. According to Article 98 of the Labor Law of People's Republic of China (PRC): "If an employer deliberately delays the conclusion of a labor contract in violation of the provisions of this law, causing damage to the workers, it shall be liable for compensation." The first paragraph of Article 82 of the Labor Contract Law of People's Republic of China (PRC) stipulates: "If the employer fails to conclude a written labor contract with the employee for more than one month and less than one year from the date of employment, it shall pay the employee twice the monthly salary." The respondent shall pay twice the monthly salary of the labor contract that was not signed with the applicant from September 4th, 2009 to October 7th, 2009, namely1842.1+1678.47+1054.88. According to Article 38 of People's Republic of China (PRC) Labor Contract Law, if the employer fails to pay the labor remuneration in full and on time, fails to pay the social insurance premium for the employee according to law, and the rules and regulations of the employer violate the provisions of laws and regulations, thus harming the rights and interests of the employee, the employee may terminate the contract. According to Item 1 of Article 46 of the Labor Contract Law of People's Republic of China (PRC), the respondent in this case shall pay economic compensation to the applicant when dissolving the labor contract. According to the provisions of Article 47 of the Labor Contract Law of People's Republic of China (PRC) on the calculation method of economic compensation, the applicant's employment in the respondent's company from August 3, 2009 to March 5, 20 10 belongs to "more than six months but less than one year", and the respondent should pay the economic compensation to the applicant 1994.83 yuan. 4. The respondent shall reissue social insurance for the applicant. Because the applicant entered the company of the respondent, the respondent did not apply for social insurance for the applicant. According to Article 72 of the Labor Law of People's Republic of China (PRC) and relevant social security laws and regulations, the applicant requires the respondent to reissue various social insurances since he entered the factory in August 2009, and pay all social insurance premiums in full. Five, the respondent shall pay high temperature subsidies to the applicant. According to Item 7 of Article 4 of the Notice on Further Strengthening the Summer Heatstroke Prevention and Cooling in Workplaces and the Notice on Promulgating the Standard of High Temperature Allowance in Guangdong Province, the company shall pay the high temperature allowance to the applicant in August, September and 10 according to law: in order to safeguard the legitimate rights and interests of workers in 300 yuan, the applicant shall, in accordance with the Labor Dispute Mediation and Arbitration Law of People's Republic of China (PRC), the Labor Law of People's Republic of China (PRC) and the Labor Contract Law of People's Republic of China (PRC), etc. Because you haven't investigated this case, and you haven't consulted your relevant evidence. Therefore, we don't comment on the facts and basis of your written arbitration. As far as the format is concerned, VCVC's answer above has explained some arbitration skills-winning = sufficient evidence+effective appeal+rich skills+judge's quality! ! . And this comrade summed up three very classic. You just don't understand. Of course, this is a professional problem, and it is not bad that you can write this level. I wish you a satisfactory solution to the problem! !