6 applications for industrial injury arbitration

Application for arbitration of work-related injuries 1

Applicant: _ _, male, 48 years old, living in Group 5, Zhangwuzhai Village, Yuanfang Township, Kaifeng County.

entrusted agent: Wang _ _, lawyer of Henan liaoyuan law firm.

respondent: Kaifeng zhongfa construction engineering co., ltd.

legal representative: Wu x, manager of the company.

company address: No.9, Sanlipu, Kaifeng.

Application request:

1. Request for ruling that the respondent should compensate the applicant for medical expenses of 15,69. 5 yuan, the food subsidy is 756 yuan, and the transportation fee is 1 yuan. During the shutdown with pay, the salary is 13,65 yuan, the nursing fee is 5,178 yuan, and the follow-up treatment fee is 6, yuan. The above * * * is 42,283 yuan. 5 yuan.

2. Compensation for the applicant's disability allowance, disability allowance and work-related injury medical allowance. The above specific amounts will be determined after the appraisal results come out.

Facts and reasons:

The respondent contracted the construction project of Building No.1 in Zhengyang Community in 2__, and the applicant started construction for the respondent on October 8, 2__, and at 9 o'clock on the evening of March 19, 2__, the respondent forced the applicant to take risks in construction, causing the applicant to fall from the third floor, resulting in the fracture of his toe bone and his right root bone.

the applicant applied to Kaifeng labor and social security bureau for work-related injury identification in July, 2, and was identified as a work-related injury in September.

since the accident, the respondent has refused to pay any compensation and has no choice but to apply to your institute for arbitration.

To sum up, the applicant is injured at work and should enjoy the company treatment according to law. Please support the applicant's application to protect the legitimate rights and interests of migrant workers.

This is to

Kaifeng Labor Arbitration Commission

Applicant: _ _ _ _ September 24, 2

Application for Arbitration of Work-related Injury 2

Applicant: _ _, male, Han nationality, born on July 18, 1966, originally from Urumqi Huatong Toyota Automobile Service Co., Ltd., address: Xinjiang Uygur Autonomous Region.

Legal representative: Li Jianping, Urumqi Huatong Toyota Motor Service Co., Ltd.

Requested matters:

1. The respondent paid the unpaid salary of RMB 1,. Yuan to the applicant,

2. The deducted business trip allowance and the applicant's business trip pad payment of RMB 5,. Yuan were paid,

3. The economic compensation was paid for 2 months (the monthly salary was RMB 5,. Yuan).

Facts and reasons:

The applicant officially went to work as the deputy general manager of Li Jianping Huatong Toyota Travel Automobile Service Co., Ltd. in June, 2. At that time, due to the irregular operation of the company, no labor contract was signed. During his tenure, the applicant worked hard to make suggestions for the company, and held a series of activities after the approval of the general manager, which gradually developed the company from the initial few cars to more than 7 cars now.

This year, I completed the Spring Festival travel rush for the company. Due to the delay in licensing the new car of the company, I didn't arrive at the scheduled time. The scheduled task was 1 million yuan, and 7, yuan was actually recovered. Excluding the expenses, the net profit of each car still reached 1, yuan. This profit was unprecedented for the respondent Li Jianping Huatong Toyota Travel Automobile Service Co., Ltd., but the respondent deducted my salary for this reason.

Based on the above facts, according to the Labor Law of the People's Republic of China, the Measures for Economic Compensation for Breach and Termination of Labor Contract and other relevant provisions, we file a lawsuit against you, request a ruling according to law, and support the applicant's request.

applicant:

October 21, 2

Application for Arbitration of Work-related Injuries 3

Complainant: _ _ _ _ _ _ _ _ _ _ _ _ _, male, Han nationality, _ _ _ _ _ _ _ _ _ _. __________， Attorney of _ _ _ _ _ _ _ _ _ _ Law Firm

Tel: _ _ _ _ _ _ _ _ _ _ _

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

legal representative: _ _ _ _ _ _ _ _ _ _ _ _ _ Title: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ General Manager

Address: _ _ _ _ _ _ _ _ _ _ _ _.

legal representative: _ _ _ _ _ _ _ _ _ _ _ _ _ Title: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ General Manager

Address: _ _ _ _ _ _ _ _ _ _ _ _.

2. request the defendant to pay the complainant's follow-up treatment fee of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

3. request the defendant to pay the social insurance premium (including basic old-age insurance, basic medical insurance, industrial injury insurance and unemployment insurance) that the complainant has been insured since _ _ _ _ _ _ _ _ _ _ _ _ _ _.

4. Request a ruling that the defendant should pay the complainant twice the monthly salary due to the failure to sign a written labor contract with the employee, that is, the salary compensation for _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

5. Request an award that the defendant should pay the economic compensation of RMB _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

6. Request for a ruling that the defendant should pay the overtime pay to the complainant from _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

this is to the

__________ _ _ Municipal Labor Arbitration Commission

Complainant: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. List of evidence

an application for arbitration of work-related injuries

Applicant:

ID number:

Address:

Respondent: _ _ _ _ _ _ _ _ _ _ _ Building Materials Co., Ltd.

Address:

Legal representative:

2. Request the respondent to immediately pay the applicant a one-time disability grant, a one-time medical grant, a one-time disability employment grant, medical expenses, appraisal fees, nursing fees, nutrition fees, hospital food subsidies, transportation fees, unpaid wages due to shutdown, second operation and other expenses * * * totaling 338,187 yuan.

Facts and reasons:

On March 1, 29, the applicant went to the respondent to work as a driver, and both parties signed a labor contract on the day of work, but both contracts were taken away by the applicant. Until the contract was terminated, the respondent failed to handle social insurance matters for the applicant according to the law. At noon on April 1, 21, The applicant was driving the respondent's sug825 _ _ truck to deliver goods to the warehouse directly under COFCO in the development zone, and was hit by a sug863 _ _ heavy dump truck at the intersection of a certain avenue and a provincial road, and the road traffic accident was proved by the development zone brigade of the traffic patrol detachment. After the applicant was injured, he was sent to the 149 Hospital of the People's Liberation Army for treatment. During this period, he spent nearly 6, yuan on medical expenses and was diagnosed as a fracture of the right femoral shaft and an open comminuted fracture of the right tibia by the 149 Hospital. As a result, the applicant can't live independently and normally, and needs special people to take care of his daily life. So far, his legs and feet are still inconvenient to move. After his condition is stable, the applicant applied for work-related injury identification at the work-related injury identification office of the Municipal Human Resources and Social Security Bureau. The work-related injury identification office of the Municipal Human Resources and Social Security Bureau made a work-related injury identification decision in accordance with the law, identifying the injured parts and injuries of the applicant as work-related injuries. On May 17, 212, the Lianyungang Labor Ability Identification Committee made a work-related certificate. Because the respondent did not handle social insurance matters for the applicant, the applicant could not get relevant insurance benefits after being injured. Therefore, the applicant consulted the respondent for many times to discuss specific compensation matters. Unfortunately, the applicant has not received any compensation from the respondent so far. To sum up, the respondent's behavior has seriously violated the applicant's legitimate rights and interests. In order to safeguard the applicant's legitimate rights and interests, according to the relevant provisions of Chinese laws, we hereby submit an arbitration application to your Committee, requesting to support all the applicant's requests.

__ Municipal Labor and Personnel Dispute Arbitration Commission

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

Respondent: _ _ _ _ Logistics Co., Ltd.

Domicile:No. _ _ _ Road, _ _ _ District, _ _ _ __

Legal Representative: Luo _

Arbitration request:

1. Request for a ruling to dissolve the labor relationship between the Applicant and the Respondent.

2. Request the ruling that the respondent pays the applicant the double wage difference of 49,5 yuan (4,5 yuan/month ×11 months) for 11 months (from September of _ _ _ _ to August of _ _ _ _ _ _ _ _) when the labor contract is not signed;

III. Request the ruling that the respondent pays the applicant 27, yuan (4,5 yuan/month ×6 months) for the period of shutdown with pay;

iv. Requesting an adjudication that the respondent paid the applicant 36,935.59 yuan for medical expenses, 1,378 yuan for transportation expenses, 5,145 yuan for hospital food subsidies (5 yuan/day ×7%×147 days) and 39 yuan for labor ability appraisal;

5. Request the ruling that the respondent pays the nursing fee of 147,6 yuan (4,1 yuan/month ×3%×12 months× 1 years) to the applicant;

VI. Request the ruling that the respondent pays the applicant a one-time disability allowance of 81, yuan (4,5 yuan/month ×18 months);

VII. Request for ruling that the respondent pays the applicant a disability allowance of 45, yuan (4,5 yuan/month ×75%×12 months× 1 years);

VIII. Request for ruling that the respondent shall pay the applicant a one-time medical subsidy of 54, yuan (4,5 yuan/month ×12 months);

the above items total 819,198.59 yuan.

Facts and reasons:

Applicant Liu _ _ joined Respondent _ _ _ _ Logistics Co., Ltd. in August of _ _ _ _ _, working as a porter, with a monthly salary of 4,5 yuan, but the Respondent has never signed a labor contract with the Applicant. At 9: a.m. on January 4th, _ _ _ _, Liu _ _ fell off a 5-meter-high cargo pile while loading and unloading goods in No.F1 warehouse of the company's warehouse. At that time, he was taken to the First Affiliated Hospital of Sun Yat-sen University by 12 ambulance for treatment, and was diagnosed by the hospital as: 1. Severe open craniocerebral injury, 1. Epidural hemorrhage caused by right frontal temporal lobe contusion, 2. Subarachnoid hemorrhage caused by left temporal lobe contusion, 3. Skull base. 2. Traumatic wet lung and hemoptysis in the right upper middle lung; 3. Fracture of right ribs 6 and 7; Fourth, there is acromioclavicular dislocation; Five, the right acetabular avulsion fracture. Because the applicant could not afford the cost of continuing treatment, he was forced to leave the hospital. The applicant was hospitalized for 147 days and needed nursing during hospitalization. The hospital suggested continuing rehabilitation treatment, strengthening nutrition and needing special care. On March 1st, _ _ _ _, the applicant's injury accident has been recognized as a work-related injury accident. On July 29th, _ _ _ _ _, the applicant was appraised by the Labor Ability Appraisal Committee of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

based on the above facts and in accordance with the Labor Contract Law, Regulations on Work-related Injury Insurance and other relevant laws and regulations, in order to safeguard their legitimate rights and interests, the applicant hereby submits the above arbitration request and applies to your arbitration commission for labor arbitration, requesting an early ruling according to law.

this is to

salute to the labor dispute arbitration Committee of _ _ _ _ _ _ _ District

Applicant: Liu __

Application for arbitration of work-related injuries 6

Cause of action: dispute over treatment of work-related injuries

Applicant: Ji Junjun, male, born on August 12, 1982, Han nationality.

Work unit: Longhua Company, heshun county, Shanxi Province. Nature of employment: appointment system.

Address: Libao Village, Dahuaishu Town, Hongtong County, Shanxi Province.

Respondent: Longhua Company, heshun county City, Shanxi Province

Address: heshun county City, Shanxi Province

Request for labor arbitration:

1. Request for ruling to terminate the labor relationship between the applicant and the respondent.