Litigation Form 3 Written Document

1. I'd like a model complaint for civil action.

Plaintiff: *, male,1born in June 1964, Han nationality, employee of * * coal mine of * * mining group, living in the north dormitory of * * coal mine of * * mining group.

Defendant: Tao Zhuang Coal Mine, a mining group.

Legal Representative: *, mine manager.

ask

1, ordering the defendant to arrange the plaintiff to work normally;

2. The defendant was ordered to pay the plaintiff a one-time disability allowance of 10600 yuan;

3. Order the defendant to pay the old-age insurance premium, unemployment insurance premium, medical insurance premium and work-related injury insurance premium for the plaintiff;

4. Adjudicate the defendant to reissue and deduct the plaintiff's work injury allowance and disability allowance;

5. The litigation expenses shall be borne by the defendant.

Facts and reasons

1994 65438+February, the plaintiff and the defendant established labor relations and engaged in coal mining in the defendant's coal mine. During the establishment of labor relations between the plaintiff and the defendant, there were three industrial injuries. 1May, 996, which caused right wrist fracture during underground coal mining; 1September, 1997, he was hit by gangue while mining coal underground, resulting in the fracture of the eighth right rib; 19981110 was hit by gangue during underground coal mining in October, resulting in a fracture of the right hip. Because the plaintiff was seriously injured and unable to work, the defendant arranged for the plaintiff to rest at home. On September 26th, 2000, the defendant appraised the plaintiff's disability, which constituted a five-level disability. In May 2003, the defendant reexamined the plaintiff's disability in the Mine Hospital of * * Mining Group. In June, 2003, 65438+ 10 and 3 1 informed the plaintiff that the reexamination result was grade 7 disability. On June 5, 2003, when the plaintiff received his salary, the defendant claimed that he would no longer pay the plaintiff work-related injury benefits from June 65438+ 10. The plaintiff applied to the Labor Dispute Arbitration Commission of * * City for arbitration on June165438+1October 65438+July 2003. * * On February 25th, 2004, the Labor Dispute Arbitration Commission served the plaintiff with the award (2003)* Lao Cai Zi No.97.

To sum up, the labor legal relationship between the plaintiff and the defendant has been established, and the personal injury suffered by the plaintiff at work has constituted a work-related injury. The defendant cannot terminate the labor contract with the plaintiff, and the plaintiff should enjoy disability treatment according to law. Therefore, according to the provisions of the Labor Law of People's Republic of China (PRC), we request your hospital to make a judgment on the plaintiff's above-mentioned litigation request according to law.

I am here to convey

* * District People's Court of * * City

Prosecutor: * *

March 2(nd), 2004

2. How to write a complaint sample, that is, a complaint sample:

Plaintiff: _ _ _ _ _ _

Defendant: _ _ _ _ _ _

Claim: _ _ _ _ _ _ _ _ _ _ _

Facts and reasons: _ _ _ _ _ _ _ _ _ _ _

Evidence and source, name and address of witness: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

I am here to convey

_ _ _ _ _ People's Court

Prosecutor:

Date, year and month

Attachment: A copy of this complaint.

Note: This complaint form can also be applied to citizens' economic litigation.

Extended data:

The complaint shall include the following contents:

(1) Basic information of the parties. Citizens shall specify their name, gender, age, nationality, work unit, position, address and contact information; The legal person shall specify the full name, domicile, name and position of the legal representative, name and position of the entrusted agent, and the lawyer shall specify the law firm where he is located;

(2) Having specific and clear opinions;

(3) Having the facts and reasons on which the prosecution is based;

(4) Evidence and sources of evidence;

(5) The signature and seal of the parties and the date of signature.

References:

Sogou encyclopedia-complaints

3. How to write a sample lawsuit, that is, a sample indictment: plaintiff: _ _ _ _ _ _ defendant: _ _ _ _ _ _ claim: _ _ _ _ _ _ _ _ facts and reasons: _ _ _ _ _ _ _ _

The complaint shall include the following contents: (1) Basic information of the parties. Citizens should indicate their name, gender, age, nationality, work unit and position, address and contact information, legal persons should indicate their name, domicile, legal representative's name and position, and lawyers should indicate their law firms. (2) Having specific and clear opinions; (3) Having the facts and reasons on which the prosecution is based; (4) Evidence and sources of evidence; (5) The signature and seal of the parties and the date of signature.

References:

Baidu encyclopedia-complaints.

4. Plaintiff in the complaint: name, gender, date of birth, nationality, education level, work unit, occupation and address. (If the plaintiff is a unit, the name of the unit, the name and position of the legal representative and the address of the unit shall be stated. )

Defendant: name, gender, date of birth, nationality, education level, work unit, occupation and address. (If the defendant is a unit, the name of the unit, the name of the legal representative, position and address of the unit shall be stated. )

Request: (state the purpose of bringing a lawsuit to the court)

Facts and reasons: (state the factual basis and legal basis of the prosecution or litigation request, including evidence, witness's name and contact address)

I am here to convey

Xxxx people's court

Plaintiff: (signature or seal)

Xxxx year x month xx day

Attachment: 1 X copies of this indictment (the number of copies is determined according to the number of defendants);

2.xx pieces of evidence;

Xx copies of other materials.

(Note: The format of the indictment in civil, administrative and criminal private prosecution cases is basically the same)

5. How to write a model civil litigation document: Appellant: name, gender, date of birth, nationality, education level, work unit, occupation and address.

(If the appellant is a unit, the name of the unit, the name and position of the legal representative and the address of the unit shall be stated. Appellee: name, gender, date of birth, nationality, education level, work unit, occupation and address. (If the appellee is a unit, the name of the unit, the name and position of the legal representative and the address of the unit should be stated) The appellant refuses to accept the judgment of the XXXX People's Court (specify the name of the court of first instance) on the case of XXXX (specify the cause of action, that is, the nature of the dispute), and now appeals. The appeal request and reasons are as follows: Request: (specify the purpose of the appeal) Facts and reasons: (specify the factual basis and legal basis of the appeal, and address the appellant of the people's court of XXXX to the facts ascertained in the judgment of first instance, the problems existing in the applicable law or the trial procedure and the reasons for misrepresentation): (signature or seal) XX, XXXX Attachment: X copies of this appeal (the number of copies shall be determined according to the number of appellees).

(Note: The appeal forms of civil, administrative and criminal cases of private prosecution are basically the same).

6. Model complaint, model civil complaint (infringement)

Plaintiff: Chang XX, male, Han nationality, 28 years old, living at Nanjing Road 10. XX garden in XX district, building x, XX.

Defendant: Beijing XX Property Management Co., Ltd.

Address:No. XX, Floor XX, Block X, XX Street, XX District, Beijing.

Legal representative: XXX, telephone number of manager: XXXXXXXX.

Cause of action: infringement dispute

ask

1. Request the court to order the defendant to compensate the plaintiff for the loss of 54,000 yuan;

2. Request the court to order the defendant to compensate the plaintiff for mental damages of 2000 yuan;

3. Request the court to order the defendant to bear the legal costs of this case.

Facts and reasons

The plaintiff lives at 10. XX (three-bedroom, 90 square meters), Building XX, XX Garden, XX District. In mid-September 2007, the defendant tried to supply water to the heating system of the building. The plaintiff found two leaks in his heating system, so he found a repairman to repair it on September 15. The repairman (Master X) suggested that the system valve must be closed for maintenance. The plaintiff then informed the defendant to close the water valve, and the defendant claimed that the water diversion valve of the plaintiff's house was in XX, building XX. Because there is no one in the house, I can't contact, so I can only close the main valve, but according to the arrangement, I can't stop the main valve on the same day, but I can only close it the next day. The next day (/kloc-September 6), the defendant closed the main valve of the building and went to the plaintiff's home to guide drainage. The plaintiff started to drain water from 16 in the morning 10, and there was no water at the drainage joint until around 23: 00 in the evening. After 9 hours, there was no water at the loose joint. At 8 am 15 on the 22nd, the plaintiff's parents went out to buy food. When they came back at 9 am 15, they found that the house had been flooded, and the water depth was more than 15 cm. Indoor furniture, floor and bottom wall are all soaked in water, and water is sprayed at the joints. Afterwards, the plaintiff's parents quickly informed the defendant and struggled to find water. It was verified that the accident was caused by the defendant opening the main valve privately.

The plaintiff is the owner of the defendant. There is a property service contract relationship between the plaintiff and the defendant. The plaintiff has never paid the property fee. The defendant shall provide the plaintiff with safe, meticulous and earnest property services. However, in this incident, the defendant opened the valve without notice due to negligence, which caused great property losses to the plaintiff and should be fully liable for compensation according to law. And the plaintiff 10 just moved in at the beginning and was soaked. Many commemorative photos and certificates are everywhere.

To sum up, the plaintiff sued your court to protect his legitimate rights and interests, and hoped that the judgment would be as requested.

I am here to convey

XX District People's Court of Beijing Municipality

Witness: (my signature)

date month year

7. How to write a complaint letter and what is the format of the complaint letter?

Plaintiff: name, gender, date of birth, nationality, native place (omitted), occupation, work unit, address and contact information.

Defendant: name, gender, date of birth, nationality, native place (omitted), occupation, work unit, address and contact information.

Litigation request:

1, the original judgment divorced the defendant;

2. Divide marital property according to law;

3. The legitimate daughter (son) XXX was raised by the original (defendant) and was sued by the original (defendant) for payment of maintenance.

Facts and reasons:

Describe the facts and reasons of divorce here, including when to get married, the basis of marriage, the feelings after marriage, the facts and reasons for the breakdown of husband and wife's feelings, what property the husband and wife have, how old the children are and so on. )

According to the provisions of Article 108 of the Civil Procedure Law of People's Republic of China (PRC), a lawsuit is hereby filed. Please judge according to law.

I am here to convey

XXXX people's court

Tangible person: XXX

date month year

Attachment: 1, one copy of this certificate;

2, a piece of evidence.