How is the indictment written? Can you give me a sample?

Hello, the answer is as follows, and a complaint sample is attached:

Civil appeal

Plaintiff: XX, gender: male, ID number: XX, birth: 1963 65438+ 10/2, nationality: Han nationality, address: XX, work unit: Chengdu Branch of Shenzhen Color Life Property Management Co., Ltd., contact information: XX.

Defendant: Shenzhen Cai Life Property Management Co., Ltd. Chengdu Branch.

Legal Representative: Chang Rong.

Address: Unit Jinshanghua 1, No.8 Dachuan Lane, Jinjiang District

Tel: XX

Litigation request:

1. Require the company to return the lost time fee of 2300* 10=23000 yuan from August 29th, 2003 to July;

2. If the employer fails to conclude a labor contract with the employee within one year from the date of employment, it shall be deemed that the employer has concluded an open-ended labor contract with the employee.

Facts and reasons

On August 29th, 20 12, the plaintiff Zhang and the defendant had a dispute over borrowing a stool (daily work content) during working hours in Zhonghe Kasmo Community, so they fought with me by virtue of their height and size, which caused great harm to my health. Under the mediation of Luo Huachun, the director of the company, Luo Huachun arranged for Mr. Mao, the security department, to take me to Shuangliu County Second People's Hospital for head CT and knee X-ray examination. At the same time, Wang Tianquan, a hospital doctor, issued a certificate of admission to Mr. Mao, the security department, and explained that he needed to be hospitalized for observation before he could identify the injury. Mr Mao stayed at that time and left alone. I called 1 10, and then the police called me to the Zhonghe police station. I explained the situation to the Zhonghe police station. After the host of Zhonghe police station received the alarm, Deng Yong and I reached an agreement: Deng Yong took me to the hospital for another check-up. If nothing happens, forget it, or ask the other party to bear the cost of examination and hospitalization, with Luo Huachun as the witness. However, Deng Yong refused to take me for a checkup and didn't pay for hospitalization. Since then, the unit has been ignored. Luo Huachun, the director of the unit, unilaterally asked me not to go to work, but did not issue a formal letter of dismissal.

I have no money to check myself, and life is very difficult. Because of the injury it caused, my head hurts (Deng Yong punched me on the head many times, and Deng Yong accepted it, which can be confirmed by the video). I really can't afford to pay for hospitalization. Regarding the above facts, there are three copies of the inspection report of the Second People's Hospital of Shuangliu County, the admission certificate issued by the Second People's Hospital of Shuangliu County, the patrol (handover) registration form and the agreement, which are confirmed by the video data of Zhonghe Kasmo Community (I have no right to retrieve it).

2065438+0 On August 26th, 2003, Chengdu Labor and Personnel Dispute Arbitration Commission held a hearing and ruled that I had a labor relationship with Shenzhen Color Life Property Management Co., Ltd. Chengdu Branch from March 22nd, 20th12 to September 24th, 20th12, and asked the company to pay me double salary of 904 1.75 yuan for five months. However, I am not satisfied with the arbitration commission's ruling on lost time and the fact that I have an open-ended contract relationship with the company. The reasons are as follows: 20 12 After I was injured on August 29th, the company ignored me because I had no money to give to the hospital. 654381lived in the company before October 23, and was unable to work due to injury. On the evening of October 23rd, 65438/KLOC-0, the company's party Luo Huachun and Director Mao came to beat me, kicked me out of the company and told the security guard not to let me in because they received the first court summons (which I sued). As for the company's proposal to publish the Notice on the Dismissal of Hu Lele and Zhang on the company bulletin board on September 24th, the company didn't inform me, and I didn't know Hu Lele at all. The notice was purely fabricated by the company. From August 29th, 20 12 to July, 20 13, I was unable to go to work due to injury, and I have been claiming rights from the company.

To sum up, I was violently injured by my workmates while performing my duties, not of my own making. Therefore, the company should pay me 23,000 yuan for lost time during the healing period from August 29th, 20 12 to July, 20 13, and should consider that I have formed an open-ended labor contract with the company and should continue to perform the labor contract.

I am here to convey

People's Court of High-tech Industrial Development Zone

Prosecutor:

20 13 September 18