The indictment, also known as the pleadings, refers to the citizens or legal persons because of their legitimate rights and interests are infringed upon to the people's court to file a lawsuit against the company's request for the instrument, the following I would like to introduce to you about the indictment of the company model essay of the information, I hope to be helpful to you.
Sue the company model essay a
Plaintiff: ___ (name), ___ (gender), ____ year ___ month ___, Han nationality, cultural level ____ , work unit ____ , position ____ , address: ________________
Defendant: ___ ( Name), ___ (gender), ____ (name), ____ year ___ month ___, Han nationality, cultural level ____ , work unit ____ , position ____ , address: ________________
Requests:
1, the judgment of the defendant to pay back the arrears of ___ yuan and interest ___ yuan.
2. Judgment that the defendant bears all the costs of this case.
Facts and reasons:
200_ year _ month _ day, the debtor ___ from the plaintiff borrowed RMB ___ million yuan, and on the spot to the plaintiff to write a note. However, to the repayment date, the defendant to various reasons and excuses for delayed repayment of the debt, its behavior seriously damage the legitimate rights and interests of the plaintiff.
Now the court judgment defendant ___ repay the plaintiff ___ RMB ___ million yuan, and pay interest, in order to safeguard the plaintiff's legitimate rights and interests.
Hereby
____ People's Court
Plaintiff: ___
____ year ___ month ___ day
Attachments: a copy of the complaint ___ (according to the number of defendants to determine the number of copies);
Second, a copy of the evidence (loan notes for evidence);
Sue the company model two
Plaintiff: Feng Moumou, male, born on February 7, 1988, Han nationality, living in Anqing, Anhui Province, a road.
Defendant: Wuhan a limited company, domicile in Wuhan City, Hanyang District ___.
Legal representative: Ma Moumou, contact number 13816011111
Requests:
1, the termination and termination of the plaintiff and the defendant on February 11, 2012 entered into the sock knitting machine Lease Contract ;
2, the defendant was ordered to return the plaintiff's sock knitting machine deposit of 276,000 yuan and bear the consignment of sock knitting machine of 13,080 yuan ;
3, the defendant's sock knitting machine. p>
3, the defendant to bear all the litigation costs.
Facts and reasons:
February 11, 2012, the plaintiff and defendant signed a sock knitting machine rental contract. February 11, 2012, February 18, the plaintiff according to the agreement of the contract, successively cash and construction bank transfer to the defendant to deposit 276,000 yuan sock knitting machine equipment deposit ****. February 17, 2012, February 29, the defendant Successively through the fast state logistics company will 6-3 type sock knitting machine equipment *** count 28 units and accessories sent to the plaintiff, consignment fee *** count 7080 yuan paid by the plaintiff. However, the 28 sock knitting machines supplied by the defendant were old machines and were three nos. and had no motors. The products produced by the defendant's sock knitting machines are semi-finished products and require additional sewing machines, edge-cuffing machines and other related equipment to produce finished socks.
In the conclusion of the sock knitting machine rental contract, the defendant's representative Huang promised: "free to the plaintiff to provide raw materials, we provide sock knitting machine is a qualified product of the new machine". However, the sock knitting machine sent to the plaintiff, the machine is old. When challenged by the plaintiff, the defendant, Mr. Yang, claimed that "we are leasing machinery, not selling machinery to you, sock knitting machine old or new does not affect production; raw materials are not provided free of charge, we have to buy raw materials from us". The plaintiff through the costing, if the raw materials are not the defendant free of charge, according to the contract price recovery finished socks, the plaintiff has no profit, can only be a loss. Furthermore, the technical personnel sent by the defendant to the plaintiff only inspected the sock loom equipment, and did not provide technical guidance on the sock loom. The plaintiff tried to produce more than 10 pairs of sample socks and sent them to the defendant, who did not comment on them.
The plaintiff through market research, the defendant lack of integrity. Before, Chongqing City, County ___ Town, Wanjing Village, a group of Zhou Mou and the defendant signed a sock knitting machine rental contract. In the process of contract fulfillment, the defendant to product quality is not qualified and other kinds of . The defendant refused to recover the finished socks, preventing the fulfillment of the contract.
In the case of the purpose of the contract can not be realized, the plaintiff according to the two sides entered into a sock knitting machine leasing contract, article 4, paragraph 2, "party B, if you quit, the two sides can settle the balance of each party, return party A equipment, terminate the contract and terminate the contract" agreement. The plaintiff repeatedly with the defendant to discuss the cancellation and termination of the sock knitting machine lease contract, the defendant did not deny. The plaintiff repeatedly called the defendant to terminate and terminate the lease contract, will send all the sock knitting machine to the defendant, the defendant asked the plaintiff to state in writing that they are not capable of production. Unable to do anything, on March 22, 2012, the plaintiff through the express delivery to the defendant sent the termination and termination of the sock knitting machine lease contract lawyers. And on March 24, through the swan express all sock knitting machine equipment and accessories shipped to the defendant, and telephone notification of the defendant to sign, the defendant refused to sign. Swan Express had no choice but to return the goods to the plaintiff, causing losses to the plaintiff. It further proves that the purpose of the defendant is to cheat the rent.
In summary, the defendant in order to achieve their own illegal purpose of cheating rent, lack of good faith, did not pay reasonable attention to the obligation to use deception to trick the plaintiff to enter into a contract with the contract should bear the responsibility of contracting fault. The plaintiff in the contract purpose can not be realized, according to the contract and the relevant laws and regulations, the plaintiff has the right to terminate and terminate the sock knitting machine lease contract. The defendant refused to accept all the sock knitting machine equipment and accessories, does not affect the fact that all the sock knitting equipment and accessories have been returned to the defendant. The plaintiff has the right to request the defendant to return the sock loom equipment deposit and bear the plaintiff's loss of transportation costs. The two sides can not reach an agreement, the special appeal to your court according to the law.
Hereby
The People's Court of Hanyang District, Wuhan City, Hubei Province
Sue the company model three
Plaintiff: Zhang __, female, ID number: 5102261944121 _____, address: ___ city ___ town Datian Village, No. 6 group 80, now live in ___ old woodland, Tel. :158259_____.
Defendant: China United Network Communications Co., Ltd, Chongqing Hechuan District Company, Domicile: 3-3, No. 66, Commercial Pedestrian Street, Nanjin Semi-Nancheng, Hechuan District, Chongqing City, Chongqing City, Organizational Code: 795873277,
Responsible person: Peng ___, the company's general manager.
The lawsuit requests:
First, the defendant and the plaintiff Zhang __ employment labor relations exist in fact.
Second, the defendant is responsible for the plaintiff to be disability appraisal.
Third, the defendant was ordered to the plaintiff radiation occupational disease identification, compensation is calculated separately.
Fourth, the defendant was ordered to compensate for my many times in the work of the body damage, one-time compensation for medical expenses of 10,000 yuan, follow-up treatment fee of 10,000 yuan, hospital food allowance of 50,000 yuan, nutritional expenses of 50,000 yuan, 10,000 yuan of nursing care during the hospitalization, 10,000 yuan of nursing care, lost wages: 10,000 yuan, 10,000 yuan of transportation costs, 100,000 yuan of disability compensation, follow-up cosmetic surgery fee of 15 yuan, 200,000 yuan of compensation for mental injury , totaling 610,000 yuan. (excluding radiation occupational disease appraisal compensation)
Fifth, the defendant was ordered to pay back the plaintiff's wages from January 1, 2012 to the date of termination of the employment relationship until the minimum wage of 1050 yuan per month, and according to the & lt; Chongqing minimum wage protection regulations & gt; Municipal Government Decree No. 106 stipulates that, the time of arrears of payment of more than six months, pay the workers the difference in the amount of the outstanding minimum wage 100% compensation.
Sixth, the defendant was ordered to pay the court to require witnesses to testify in court, the cost of lost wages, living expenses, car fare 200 yuan per person.
VII. The defendant shall bear the costs of the case.
Case: the provision of laborers damages and labor remuneration disputes
Facts and reasons; in August 1999, Unicom Hecheon branch in the Huayash mountain three sinks forest field Quazhaizi hilltop construction of communication network base station room, when the Unicom Hecheon branch to ask me to build the base station project for the handling of materials, cooking, and other matters, the company felt that I am loyal and honest, in February 2000, the company After the completion of the base station room needs a can for years and years, the people who do not leave the man on duty. At that time, the company's base station responsible person Zhou Tao, Zhou Ju, Peng Jing and others agreed to hire me the most suitable, because I am old, a person in the deep mountain tops quietly watch, no which young people are willing to do this kind of work, so I decided that I for the base station room as a watchman, but the person in charge of the company put forward the employment agreement in the name of my son Wang Xiaohua signed by my actual work, and at that time, this employment agreement was also signed by others, Wang Xiaohua. The agreement was also signed by others, Wang Xiaohua simply do not know, from that time to the present day, I have been sticking to the base station position for more than 13 years, in order to do this work, my husband and I specifically at the foot of the mountain to build a temporary hut to live in the perennial no lighting, are point kerosene lamps for lighting, more than a decade of suffering, life is very difficult.
May 6, 2001, the machine room antenna due to lightning strikes caused by high temperature burns, with a large number of medical expenses, August 12, 2011, in order to rule out the existence of high temperatures in the machine room security risks and open the air-conditioning to cool down, immediately the air-conditioning high-temperature impact on the ground, the whole body was scalded, facial disfigurement, the scene witnesses are Huang Wenmin, Yang Shiju, Yang Yanming, Xu Yucheng. The company maliciously delayed the denial, two times are not given medical reimbursement, scalded until now have not healed, encountered family and friends of the dislike and alienation, the heart is difficult to bear, so that my spirit has been incomparable damage.
On January 2, 2013, at 5:28 pm, a group of thieves holding steel pliers, steel saw, hand hammer and other steel, attempting to steal the air conditioning in the server room, was my immediate discovery of the rapid escape, I immediately to the Public Security Bureau 110 alarms, the Sanhui Township police station reported the case, the air conditioning in the process of me from the outdoor general into the house, resulting in a serious contusion of the chest, the back, to a large number of medical expenses, and has not been healed, the company is still the same as in the case of the air conditioning from the outdoors, resulting in severe contusion of the back, and the medical bills, until now. Not healed, the company is still maliciously delayed denial, pennies did not pay the medical expenses.
February 7, 2012, August 13, 2013, October 22, 2013, the plaintiff has been to the Third Military Medical University of Beibei, the First Affiliated Hospital diagnosed with vitiligo, scalded, vitiligo, the last review of the doctor told me that I was a number of traumatic injuries and the work environment related to radiation caused by vitiligo, which I know that my rights have been infringed upon, which I never knew before! This is something I never knew before.
In addition, the company never gave anti-radiation clothes to wear to work, long-term acceptance of the intensity of radiation, and often eat and live inside the base station, now the body has a vertigo, persistent headache, vision loss, heart discomfort, insomnia, fatigue and other phenomena, more and more serious, suspected of radiation occupational disease.
In order to claim compensation for my physical injuries, I continuously to the defendant and the city, the district petition office to put forward a request for compensation, claiming my rights, but was the company five times the police, I brought me back to the Nanjin Street police station in order to detain the police station to learn about the truth, although I did not detain me, but to give me a public security bureau of the administrative penalty, only the seal of the Nanjin Street police station, but there is no person in charge of the signature, and even more no The person being punished signed for it. The five times were:
March 4, 2012, June 28, July 22, October 25, May 18, 2013, respectively.
Even worse, on March 4, 2012, I was physically assaulted by Zhao Changchun, the person in charge of the company's office, when I was requesting compensation for my injuries, and he pushed and shoved me to the ground at the age of nearly 70, nearly killing me, and subjecting me to severe physical and mental humiliation.
The above facts are sufficient to show that the defendant and the plaintiff's employment relationship exists in fact, the defendant is required to pay the plaintiff a one-time personal injury compensation fee **** 610,000 (occupational disease identification, compensation is calculated separately.)
In summary, the people's court to support the plaintiff's request to maintain the plaintiff's legitimate rights and interests.
Hereby.
Hechuan District People's Court
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