Model complaint on treatment of industrial injury insurance

Plaintiff: xxxx, ID number xxxx, gender xxxx, born in xxx month, xxx year, and address: xxxxxxxx. Tel: Defendant: Legal Representative of xxxx Co., Ltd.: xxx, with the post of xxx. Address: xxxx Tel: Litigation Request 1. Order the defendant to pay the economic compensation of RMB xxxx immediately; Second, according to the law, the defendant was ordered to pay the salary of xxx yuan during the shutdown period; 3. According to the law, the defendant was ordered to pay a one-time disability subsidy of xxxx yuan, a one-time disability medical subsidy of xxx yuan and a one-time disability employment subsidy of xxxx yuan; Four, according to the law, the defendant was ordered to bear the appraisal fee of xxx yuan and transportation fee of xxx yuan; Third, the defendant was ordered to bear the legal costs of this case and all other legal costs. Facts and reasons: from 20 12 to 10, the defendant recruited the plaintiff to work as a sewing operator in the defendant company, with a monthly salary of about xxxx yuan. On the afternoon of 20 1 1 year/month 65438+4, the plaintiff was accidentally injured at work, which was recognized as a work-related injury on June 9, 20 1 year, and on June 0/year 1 year. Since August 20 14, the defendant no longer paid social insurance for the plaintiff and other employees, and the plaintiff terminated the labor contract according to relevant regulations, and the defendant failed to pay the plaintiff economic compensation in time. The plaintiff applied for labor arbitration on September 25, 20 14. The defendant is now required to pay economic compensation of 6 months× XXX yuan/month× 2 =xxx yuan, shutdown period of 4 months× XXX yuan/month =xxx yuan, one-time disability allowance of 7 months× XXX yuan/month =xxx yuan, one-time disability medical allowance of 5.92 months× XXX yuan/month =xxx yuan, and one-time disability employment allowance of 3 months× XXX yuan/month = XXX yuan. The plaintiff sued your hospital in order to safeguard his legitimate rights and interests, and hoped that your hospital would make a judgment according to law. To the People's Court of Shibei District: Year Month Day.

Attachment: a copy of this complaint, with evidence cases.