The reply can be written in response to the plaintiff's statement of the applicable law. In today's social life, many things that can not be reconciled need to be resolved through legal means, before the hearing will be done in advance of the defense, the following is what I have organized for you to reply to the labor arbitration, just for reference, welcome to read.

Labor Arbitration Reply Brief Part 1

Name of Respondent:

Address:

Legal Representative:

Position:

Telephone:

Appointed Agent:

Claimant:

The Claimant:

Identity Card No.:

Address:

The Claimant _______ for the _______ v. our company, now puts forward the following reply:

First, the respondent and the complainant to terminate the labor contract is not the respondent's fault, but according to the respondent and the complainant signed the "______ labor contract" respondent and the complainant each holds a labor contract, which the respondent's years of work, there is a clear agreement on the contract agreement period as of ______ on _______, _______, _______. The respondent informed the complainant that the contract would not be renewed after the expiry of the contract in accordance with the contractual agreement. As for the respondent's claim that the "__________ Training Agreement" signed with the management department of the respondent's subordinate ________ department was stamped with the special seal of the management department of the respondent's ______ department, but was not stamped with the special seal of the personnel of the respondent's department, it did not comply with Article 15 of the "Code of Practice for the Personnel Management of the respondent's ___________ department", which stipulates that the signing of a labor agreement shall be stamped with the special seal of the personnel of the respondent's department. Beyond the authority of the department, also does not comply with our internal procedures, should be invalid. Therefore, the respondent belongs to the lawful termination of the labor contract should not pay compensation to the complainant, also need not bear _____% training costs.

Secondly, in response to the complainant's request to pay the arrears of ______ ____ month ~ ____ month: daily wages _______ yuan x ____ months - paid _______ yuan = _______ yuan, ______ ____ month ~ ____ month wages _______ yuan, we do not recognize the request, we have been during the training period paid the necessary living expenses and the grade wages _______ in the wage scale.

Thirdly, we terminated the labor contract with the complainant on ______, so we did not need to pay the salary from ______ to ______, and we did not need to pay social insurance for the complainant for ______ to ______. For the year-end bonus, it is an incentive mechanism to reward outstanding employees. The complainant is not an outstanding employee and the respondent has refused to pay the year-end bonus from ______ to ______.

In view of the above reasons, the Respondent has been unable to continue to fulfill the labor contract with the Grievant, and the Respondent's termination of the labor contract is not in violation of the labor law and other relevant laws. It is hoped that the Arbitration Tribunal will support justice and reject the complainant's request for arbitration in accordance with the law.

Sincerely

________ Arbitration Committee

Respondent: (seal)

Legal representative: ______ (signature)

______ ___Month___, ___Year

Attachment: 1. A copy of the statement of defense ____.

2. Other supporting materials ___pieces

Labor Arbitration Reply Part 2

Respondent: xx Catering Company Limited

Address:

Legal Representative:

Position: General Manager

Respondent: xx Wang, Female, Domicile:

Current Address: No. xx, Hail Road, xx City, xx District

Respondent: xx Wang, Female, Domicile:

Current Address: No. xx, Hail Road, xx City, xx City, xx City, xx City, xx City, xx City, xx City

Respondent v. Respondent Labor Dispute, the respondent, based on the facts of this case and the relevant provisions of the law, put forward the following reply:

First, the respondent agrees to terminate the labor contract relationship with the respondent, but the respondent asked the respondent to pay economic compensation of 8,000 yuan has no basis. The respondent has been working for the respondent since May 20xx, and signed a labor contract. since May 20xx, the respondent has been paying social pension insurance for the respondent, and on March 25, 20xx, the respondent suffered a work-related accident, and the respondent actively paid all the treatment costs for him, and the wages were paid during the period of treatment without pay. Now the respondent voluntarily requested to terminate the labor contract, according to the relevant provisions of the Labor Contract Law, the respondent does not need to pay economic compensation to the respondent.

Second, the respondent asked the respondent to pay a one-time injury medical benefits of 42,000 yuan and a one-time disability employment benefits of 67,235 yuan, in accordance with the law. The respondent was born on January 2, 1965, January 2, 20xx reached the statutory retirement age. Article 25 of the Implementing Measures of Shandong Province for Implementing the Regulations on Work-Related Injury Insurance stipulates that: "If a worker who suffers a work-related injury terminates or terminates the labor contract with the employer and ...... reaches the statutory retirement age or has gone through the retirement procedures according to the regulations, the lump-sum work-related injury medical benefit and the lump-sum disability employment benefit will not be paid. one-time disability employment benefit." The respondent immediately terminated the labor contract with the respondent, has reached the statutory retirement age, according to the above provisions, the respondent shall not pay for the respondent one-time injury medical benefits and one-time disability employment benefits.

In addition, because the respondent has paid the work injury insurance for the respondent, the respondent should enjoy the work injury treatment, should be paid by the work injury insurance fund.

In summary, the respondent requested to terminate the labor contract, the respondent does not exist in the Labor Contract Law should be issued economic compensation, plus the respondent reached the statutory retirement age on January 2 this year, the respondent is not required to pay a one-time medical benefits for work-related injuries and a one-time disability employment benefits, the Arbitration Tribunal to ascertain the facts and make a decision in accordance with the law.

Hereby

20xx District Labor and Personnel Dispute Arbitration Committee

Respondent: xx Catering Company

March 12, 20xx

Labor Arbitration Response 3

Respondent:

Address:

Respondent:

Address:

Legal Representative Person:

Respondent, in the case of ________ v. Respondent's termination of labor contract and labor compensation, filed a reply as follows:

________ entered our company on _____ February _____ of ______, working as an accountant in the Finance Department, with a monthly salary of RMB ______. On ______ _____ January _____, ________ said that there was something at home and asked to resign from work and submitted a resignation slip, the Respondent agreed, but ________ then proposed that the Respondent should give certain economic compensation, the Respondent rejected ________'s request for compensation based on the provisions of Article 46 of the Labor Contract Law, and ________ then took a re consideration as the reason for taking back the resignation order. However, after getting back the resignation order, he did not return to our company for ______ consecutive days (from _____ to _____) and did not answer any phone calls from the company. In order to take the discipline of the company seriously, the Respondent signed the Labor Contract with the Respondent on _____ in accordance with Article 141 of the Labor Contract signed between ________ and the Respondent on _____ in ______. Article 44(1) of the Labor Contract, which states that both parties to the contract shall abide by the ________ Group Rules and Regulations (i.e., the Employee Handbook). The first paragraph of Article _____ of Chapter ____ of the ________ Group Employee Handbook clearly stipulates that an employee who is absent from work without leave for _____ consecutive days without reason, or who is absent from work for ______ cumulatively in a month, or who is absent from work for ______ cumulatively in a year, shall be removed from the workforce, and a removal from the workforce has been made against ________.

After the respondent made the notice of de-registration treatment, ________ returned to our company on ______ and carried out the handover of work, but he neither agreed to return the resignation order, nor agreed to sign for the notice of de-registration treatment and receive the salary, so our company could only set out his refusal to receive, refused to receive the situation and the witness witnessed the situation of the notice of de-registration.

The Chinese company has been working on a project for a long time.

Article 39 and Article 46 of the Labor Contract Law of the People's Republic of China stipulate that if a worker seriously violates the rules and regulations of the employer, the employer has the right to unilaterally terminate the labor contract without having to pay economic compensation.

Our company in ______ on _____ January _____ made the removal notice, had clearly required ________ as soon as possible to return to the company to settle the wages, so our company did not owe his wages intentionally, wages failed to settle the reason for his refusal to collect, so ________ request our company to pay the economic compensation for arrears of wages is no factual basis. In view of the fact that ________ had borrowed RMB ______ from our company on the grounds of something happened at home on _____, this ______ should be deducted from the wages that ________ should receive.

Article 27 of the Law of the People's Republic of China on Mediation and Arbitration of Labor Disputes stipulates that the limitation period for applying for arbitration of labor disputes is one year, and the limitation period for arbitration is calculated from the date when the parties concerned knew or should have known that their rights had been infringed. Therefore, ________'s request for the payment of wages for the untaken annual leave from _____ _____ to _____ _____ is unfounded.

With the circumstances listed in Article 40 of the Law of the People's Republic of China on Labor Contracts, the employer shall terminate the labor contract only after notifying the worker in writing in advance of thirty days or paying the worker one additional month's salary. In this case, the reason for our company to terminate the labor relationship with ________ is due to its serious violation of the company's rules and regulations, and does not comply with the circumstances stipulated in Article 40, so ________'s request for our company to pay the economic compensation for the failure to give thirty days' notice has no basis

In summary, ________'s request for a grievance has no legal or factual basis. I implore the Arbitration Commission to reject the relevant grievance request of ________ in accordance with the law.

Yours faithfully

________ Municipal Labor Dispute Arbitration Committee

Respondent: _____________ Limited

________, ________

Attached are: a copy of the statement of reply _____;

Evidentiary materials ______ copies.

Labor Arbitration Answer Letter Part 4

Respondent: xx Co., Ltd, domiciled at XX Road, XX City,

Legal Representative: xx, Chairman of the Board, Contact Tel:

Respondent: xx, male, Han nationality, born on August 10, 20xx, residing at Room xx, No.xx, XX City

Respondent sued Respondent for termination of labor relationship, wage Dispute case, now the respondent filed a reply as follows:

First, the respondent request to terminate the labor relationship of the facts and legal basis

The respondent for their own reasons on xx xx xx 20xx resigned on their own initiative, and then the two sides reached a settlement agreement on the termination of the labor contract on xx xx 20xx, both sides of the labor relationship has been lifted. The labor relationship between the two parties has been dissolved. Respondent again claimed the termination of the labor relationship, no factual and legal basis, obviously improper.

Second, the respondent claimed to pay the costs of xxx yuan has no basis

1, the respondent resigned, the two sides signed a labor contract termination agreement on the basis of consensus, clearly agreed that the respondent in the respondent's work during the wages, overtime, holiday overtime and other costs have been fully settled, the respondent has no objection, the respondent has no objection, the respondent has no objection. There was no objection from the Respondent, and the Respondent would not pursue the Respondent for any further responsibility. In this case, the two sides have reached a settlement agreement on wages, overtime wages, the agreement does not violate the mandatory provisions of the law, and there is no fraud, coercion and other circumstances, according to law.

2, the respondent claim economic compensation in law. The respondent resigned on his own initiative, and does not meet the requirements for payment of economic compensation, claiming economic compensation without legal basis.

3, the respondent claim double wages also has no factual and legal basis. First of all, the parties signed a labor contract, there is no double wages; Second, the claim of double wages has a clear ` time limit, limitation, amount limit. The respondent's claim has no factual and legal basis.

In summary, the respondent's request for arbitration has no factual and legal basis, according to the law can not be established, I implore you to reject the respondent's request for arbitration.

Hereby

xx Labor and Personnel Dispute Arbitration Committee

Respondent: xx Co.

Legal representative: Yan xx

Position: General Manager

Dear Jianghan District Labor Dispute Arbitration Committee:

The Respondent has received your notice of hearing of Jianglao Renzhong Zi (xxxx) No. 0915-1-2, and hereby, in response to the Claimant's request, the Respondent The reply is as follows:

Firstly, there exists a de facto labor relationship between the applicant and the respondent, which exists objectively, but the respondent was legally established on July 19, xxxx, and was legally revoked on November 28, xxxx, so the labor relationship between the two parties survived for the period of time from: July 19, xxxx - ... --- November 28, xxxx, and not from June xxxx to June xxxx as claimed by the applicant.

Second, the applicant's request for arbitration of the difference in double wages for the period from February xxxx to June xxxx has no factual or legal basis.

1, first of all, the respondent and the applicant did not sign a written labor contract, but according to the labor contract law, article 14, the employer from the date of employment of one year does not enter into a written labor contract with the worker, the employer and the worker is deemed to have entered into an open-ended labor contract. Since the labor contract, there is no so-called unsigned labor contract to pay double wages, and xx city intermediate people's court on the trial of labor disputes on a number of issues (wu zhongfa 『 xxxx 』 no. 87) article 18 of the provisions of the employer and the worker for more than a year did not sign a written labor contract, but the two sides are still maintaining the labor relationship, the employer does not need to pay double wages. The wages of the employer.

2, even if the request for double wages, according to the current legal provisions of the maximum is to support the double wages for 11 months from February xxxx to December xxxx, but according to the Ministry of Labor, "Interim Provisions on the Payment of Wages," the provisions of Article 3, the wage refers to the employer in accordance with the provisions of the labor contract, in various forms of payment to the workers of the wage compensation. The essence of wages is the monetary expression of the commodity value of the labor provided by the workers. The wages paid by the employer are the manifestation of this value, and the other double wages (double the difference in wages) are not the manifestation of the value of the labor provided by the laborer, and therefore do not belong to the wages, but belong to the punitive damages due to the violation of the provisions of the law by the employer. Regarding the starting point of the statute of limitations, Article 27 of the Law on Mediation and Arbitration of Labor Disputes stipulates that the statute of limitations period for applying for arbitration of labor disputes is one year. The limitation period for arbitration is calculated from the date when the parties know or should know that their rights have been infringed upon. Since the difference of double wages is not labor remuneration, then this provision should be applied, so xxxx February to xxxx December 11 months of the difference of double wages as of xxxx December has passed the arbitration statute of limitations, and as of today has been 4 years, this stage of the difference of double wages should be rejected according to law.

Third, for the applicant's request for payment of 10 months of monthly economic compensation of 3500 yuan without factual and legal basis.

1, the respondent's survival of the time is xxxx July 19 - xxxx November 28, a total of 4 years and 4 months, even if the payment of economic compensation is up to 4. 5 months of salary.

2, the applicant's average salary during the period of employment is far from 3500 yuan, the maximum does not exceed 3000 yuan.

3, xxxx June request to pay xxxx November 28 before the economic compensation has long passed the labor arbitration one year of arbitration.

4, the applicant in the job, in the work process to eat kickbacks, has been a serious violation of the company's rules and regulations and labor discipline, and suspected of violating the law, the applicant wanton absenteeism, unauthorized departure, rather than the company's reasons for its departure, the company is mindful of the old feelings of the company temporarily retains the right to its responsibility, the applicant even more not have the right to the respondent to demand the payment of economic compensation.

Fourth, the applicant proposed to pay the social insurance from July xxxx to June xxxx or pay social insurance loss without factual and legal basis.

1, the existence of the respondent time is: xxxx July 19 - xxxx November 28, even if the retroactive payment or compensation is limited to this period.

2, in accordance with the provisions of our law to make up for the social insurance, there should be an administrative body to deal with the scope of the arbitration institution and the court.

3. The request has been subject to one year of arbitration.

The end of the above, the applicant's request has no factual and legal basis, the respondent requests you to reject the applicant's request for arbitration in accordance with the law, and to safeguard the legitimate rights and interests of the respondent.

Hereby

xx City Jianghan District Labor and Personnel Dispute Arbitration Committee

Respondent: xxxx Construction and Design Company Limited

20xx x month x

Labor Arbitration Response Part 6

Respondent: xx male xxx years old xx County xxx company employees, living in xx County, xx Street x

Because of xx County XX Company v. Labor Dispute, the following reply is filed:

Respondent's termination of the labor contract with the complainant was not Respondent's fault, and Respondent and the complainant signed a labor contract in which the position of Respondent was defined xx Sales Manager, but the complainant autonomously transferred Respondent to another department after ___ months without consulting with Respondent. , without obtaining the Respondent's consent, the Complainant's practice was in violation of Article 17 of the Labor Law, the Complainant did not follow the principle of equality and voluntariness and consensus in changing the labor contract, but rather forced the Respondent to report to other departments, which was against the Respondent's will, and in the event of the Complainant's breach of contract in the first instance the Respondent was forced to resign, the Complainant suggested that the Respondent was in breach of the Article 30 of the Labor Law, which is unfounded, and since it was the complainant who was at fault first, the situation in which the respondent was forced to tender his resignation does not correspond to the situation stipulated in Article 31 of the Labor Law. The loss thus caused should not be borne by the respondent. In the absence of fault on the part of the respondent is not obliged to bear this responsibility.

The claimant's claim that the respondent worked for a company with which he was in competition and caused losses to him, and that he should be held liable for the losses, is not justified. Firstly, the resignation of the respondent was due to the fault of the complainant and there was no non-competition agreement between the respondent and the complainant, so the company in which the respondent went to work had nothing to do with the complainant and it was the right of the respondent to choose his employment freely and no one else could deprive him of it.

The complainant asked the Arbitration Committee to order the respondent to continue to perform the contract, which is also unfounded, the labor contract signed between the two parties has been terminated, the respondent is in accordance with the legal procedures will be the termination of the labor contract, the termination of the contract is in accordance with the provisions of the law, therefore, there is no labor relations between the respondent and the complainant, the complainant naturally have no way to demand the respondent to perform the labor contract. Labor contract.

In view of the above reasons, the respondent has been unable to continue to fulfill the labor contract with the complainant, I hope that the Arbitration Tribunal to support justice, according to the law to reject the complainant's request for arbitration.

Hereby

xxx Arbitration Committee

Respondent: xxx

xx, xx, xx

Labor Arbitration Response 7

Respondent: Wang xx

Residence: xx, Unit xx, No. xx Road, xxxx District

Respondent: xxxx Computer Technology Co. >

Place of Residence: No. 18, XX Road, XX Development Zone, XX District, XX City

Legal Representative: Li XX

The Respondent, in connection with the case of Labor Dispute with the Respondent, puts forward the following reply:

1. The Respondent's statement in the Civil Complaint is inconsistent with the facts in the following three points.

1, the respondent unlawfully terminated the labor contract, rather than the statement of the respondent claimed through legal channels and lawful termination. The real situation is: on February 10, xxxx, the respondent was hired to the respondent's predecessor --- xx Technology Co., Ltd. engaged in the sales business. xxxx November 30, the respondent to the respondent issued a "letter of intent to sign a labor contract," recognizing that the respondent in the company's all the The Respondent issued a Letter of Intent to Sign an Employment Contract to the Respondent on November 30, xxxx, acknowledging all of the Respondent's years of employment with the Company, and entered into an open-ended employment contract on December 27, xxxx. The labor contract stipulated that Respondent's job position was sales representative, and the workplace was xx. Respondent's monthly salary was actually a fixed salary of 5,300 RMB + commission, of which the fixed salary of 5,300 was artificially divided into two parts of 1,500 + 3,800, and the 3,800 RMB was to be exchanged for the invoices that Respondent took every month. xxxx January, without consensus with Respondent, Respondent By disallowing Respondent to receive salary from the Company in the form of reimbursement again, disguisedly reduced Respondent's fixed salary to 1,500 yuan, and divided the department for which Respondent was responsible to others, resulting in Respondent's actual on-call status, and his monthly salary was reduced from 20,000 yuan straight down to 800 yuan. xxxx At the end of May, Respondent verbally proposed to change the location of Respondent's workplace to Chongqing, but did not reach an agreement with Respondent. On June 21, xxxx, the Respondent suddenly issued a Notice of Termination of Labor Contract to the Respondent on the grounds that the Respondent had not been working in the station area (Chongqing) since June 2, xxxx and had been continuously absent from work, notifying the termination of the labor contract with the Respondent and refusing to give any economic compensation.

2, the respondent is not incompetent to work, the respondent people's civil action that the respondent is incompetent to work is not the case. The real situation is: respondent xxxx annual sales task is 65.2 million yuan, in January - June has been completed 47665990. 70 yuan, is the second quarter of the respondent xxxx sales of the Dragon Tiger list list of sales pacesetter and was informed of the commendation. Although the completion rate slipped from July to December and only $14.3 million was completed, Respondent's annual sales totaled $6,188,026,620. 80, a 95% achievement rate for the year. Therefore, Respondent relies only on its self-selected time period of July to December xxxx to calculate Respondent's sales task completion rate of 38%, which is not recognized by Respondent.

Further, the Respondent never received any notice or warning of incompetence during the period he was on duty, and the Respondent's sudden introduction of the concept of incompetence of the Respondent after arbitration and in the proceedings at the first instance was obviously with an ulterior motive.

3, the respondent did not notify the respondent transfer, the respondent in the civil suit that the notification of the respondent xxxx May 30, 2010 transfer is not a fact. The real situation is: the respondent at the end of May only oral proposal to mobilize the respondent to Chongqing work, the respondent did not agree, the respondent did not insist on formal notice. The respondent argued that the transfer was a major change in the labor contract, and according to Article 35 of the Labor Contract Law, "Changes to the labor contract shall be in writing." Therefore, the Respondent's mere verbal offer was not a notice within the meaning of the Labor Law.

Second, as to the respondent's claim, the court is requested to reject it for the following reasons:

1. The respondent's termination of the labor contract is illegal.

(1) The respondent proposed to terminate the labor contract on the ground that the respondent did not report to the resident area since June 2, xxxx, and did not apply for leave of absence to the line sales manager, and was absent from work for more than 3 consecutive days. However, the Respondent did not have any evidence to prove that the Respondent was ever formally notified to work in Chongqing. As mentioned above, the Respondent only verbally proposed to transfer the Respondent to work in Chongqing and the Respondent did not agree. In the absence of formal notification or consensus, it is impossible for the respondent to report to Chongqing, so the termination of the labor contract is not justified.

(2) the respondent's working hours for irregular working hours, the work position is a salesperson, not clocking in and out of work, do not need to report to the company every day, and do not need to report to the line sales manager every day. In addition, the respondent since January xxxx began to wait for the post (responsible for the department was divided into others), only to receive the most basic salary of 800 yuan per month, waiting for the post during the period of no work arrangements, and do not need to report to the company every day, so there is even less do not report to the absenteeism that is.

2. The respondent unilaterally transferred the job illegal.

(1) Although the labor contract: "the respondent agreed to the respondent based on the needs of management, or the applicant's ability to work, performance and health, etc., according to law, the applicant's work content, work position, workplace adjustment." And according to the Labor Contract Law, there are only three situations in which an employer may adjust a worker's job position in accordance with the law: "First, the adjustment is made by consensus with the worker; second, the employer may adjust the job because the worker is not able to perform the job; and third, the adjustment is made because of a significant change in the objective circumstances on which the labor contract was concluded." And the respondent transferred the reason does not meet any of the above three, is not the labor contract agreed in accordance with the law transfer.

(2) Although the respondent's complaint in the respondent's transfer on the grounds that the respondent is incompetent. However, the facts, as stated above, the respondent was not incompetent for work and the respondent never received notice and warning of incompetence during the posting. Respondent after the termination of the labor contract with the respondent, after labor arbitration, the first instance appeal suddenly put forward the respondent is incompetent at work, there is no factual and legal basis, and even more evidence of the fact that it is a unilateral illegal transfer.

Third, for the first arbitration award, the court shall change to the respondent shall pay the respondent unlawful termination of the labor contract double economic compensation and 50% additional compensation, and re-calculate the base of the termination of the labor contract economic compensation:

1, the arbitration committee, although it was found that the respondent did not have a consensus with the respondent and the unilateral transfer of the act of the law, but does not have any basis for the respondent unlawful transfer of the act of the respondent. Although the Arbitration Committee found that the Respondent's act of dismissing the Respondent for absenteeism after the transfer of the Respondent's post was in violation of the labor contract, the Arbitration Committee found that the Respondent legally terminated the labor contract with the Respondent in accordance with paragraph 3 of Article 40 of the Labor Contract Law, and ruled that the Respondent was only required to pay the Respondent a single economic indemnity, which deprived the Respondent of the right to receive the double indemnity for the dismissal, and was a mistake in the determination of the facts. The right, is to find the facts wrong, the application of the law is improper, please the court according to law to re-examine.

2, the Arbitration Commission in the calculation of compensation for termination of labor contract wage base is wrong, did not take the respondent monthly reimbursement of invoices received 2800 yuan as the respondent's salary composition to be calculated, and then the respondent calculation of the base of the separation of the economic compensation was reduced by 3,800 yuan, it is unfair. The Court is requested to ascertain that: from January to December, xxxx, the Respondent's fixed salary was 5,300 yuan, of which 3,800 yuan was required to be exchanged for invoices, but it was only a means of tax evasion by the Respondent, and as long as the Respondent provided invoices for meals, transportation, and lodging, and did not need to actually travel on business, the Respondent reimbursed the invoices. The payment was fixed monthly and the amount remained the same. The name of the reimbursement, in fact, the respondent's fixed salary income.

3, the respondent did not explain the reasons to the respondent and the respondent consensus, from January xxxx to let the respondent to standby (the respondent responsible for the department assigned to others, and did not give the respondent to arrange other work). As a result, the Respondent was only able to receive the minimum wage of $800 per month. Therefore, when calculating Respondent's average salary for the 12 months prior to separation, Respondent's sales commission salary for January-June of XXXX should be retroactively calculated in accordance with the appropriate standards; otherwise, the amount of Respondent's severance pay reimbursement will be directly reduced. (Respondent proposes to use the commission of the month before the respondent's actual pending work as the compensation standard).

4, according to the supreme court on the trial of labor dispute cases on the application of law interpretation of article 20: "for the recovery of labor compensation, pensions, medical fees, as well as industrial injury insurance treatment, economic compensation, training fees and other related costs, etc., the case, the amount of payment is not appropriate, the people's court can be changed."

In summary, the respondent's application is not in accordance with the facts and has no legal basis, and requests the court to reject the respondent's litigation request in accordance with the law, and reopen the arbitration commission's improper award in accordance with the law, and safeguard the respondent's rights and interests in accordance with the law.

Respondent: Wang xx

Agent: Shen xx lawyer

xxxx November 5