Applicant: Xu xx, male, born in July 1966, formerly deputy general manager of xxX Travel Automobile Service Co., Ltd., living in. No. xx Lane, xxX Village, xx City, XX Province. Tel: 13xxx.
Respondent: xx Travel Automobile Service Co., Ltd., address:No. xx Street, xxX District, xX City (mailing address: Ding Dong Building,No. xx Road)
Legal Representative: Chen xx Tel: 0355-7xxxx13xxxx.
Requested items:
1. The Respondent pays the owed salary of RMB xxx to the Applicant;
2. Pay RMB xxx yuan after deducting the applicant's travel allowance and the applicant's travel mat payment;
3. Pay economic compensation for xx months (monthly salary of xxx yuan, 25% of salary) * * XXX yuan;
4. The respondent shall bear the labor arbitration fee;
Facts and reasons:
In September, 2005, the applicant officially went to work for the respondent xxx Travel Automobile Service Co., Ltd. as the deputy general manager. At that time, due to the irregular operation of the company, no labor contract was signed. During his tenure, the applicant worked diligently 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 70 cars now.
This year, I completed the Spring Festival travel rush for my company. I didn't arrive as scheduled because of the delay in registering the company's new car. The scheduled task is xxx million yuan, and the actual recovery is xxx million yuan. Excluding expenses, the net profit of each car can still reach xx million yuan. Such a profit is unprecedented for the respondent xxx Travel Automobile Service Co., Ltd., but the respondent has deducted my salary, subsidies and business expenses that should be reimbursed on this ground.
Based on the above facts, according to the Labor Law of People's Republic of China (PRC), the Measures for Economic Compensation for Breach and Termination of Labor Contract and other relevant regulations, we file a lawsuit against you, requesting a ruling according to law and supporting the applicant's request.
I am here to convey
Xxx district labor bureau labor arbitration commission
Applicant Xu x x
2006 1 1 8th of the month
Look, I'll steal it, hehe. ...