Legal Counsel Recent reply:
Applicant: Mr. Pan, Han nationality, born on August 1, 1966, with address of Group 9, Yaozhuang Village, XX Town, XX County, Hubei Province. contact number: Respondent: Hebei XX Construction Engineering Co., Ltd., address: No. 000, Hengshan West Road, Zhengding County, Hebei Legal representative: Han XX Contact number: Request: Request to confirm that there is a factual labor relationship between the applicant and the respondent. Facts and reasons: The applicant came to the construction site of Hebei XX Engineering Co., Ltd. in Xinhua District, Shijiazhuang City to work on May 23, 2011 through the introduction of fellow villagers. On the morning of June 7, 2011, when he went to work and walked to the basement door of the construction site, Zhang XX, the monitor, asked the applicant to clean the basement formwork, and then asked the applicant to pry the formwork off the wall after cleaning, In the process of prying, he fell off the iron pipe with too much force, and was immediately sent to Hebei People's Hospital by the workmates. After the diagnosis of Hebei People's Hospital, it was confirmed that the applicant constituted a lumbar fracture. After the accident, he stopped contact with the applicant after paying the hospital RMB 00 on the site. The applicant has repeatedly contacted the person in charge of the construction site, Manager Lu, who said that the injury and hospitalization of the applicant had nothing to do with the fall injury on the construction site. The applicant has failed to negotiate with him for many times. Because he is unable to bear the heavy medical expenses, he has to go home to recuperate. To sum up, the applicant was injured while working on the construction site undertaken by the respondent, and the applicant should perform the management and safety guarantee obligations for the project contracted by him. Therefore, the applicant and the respondent have formed a de facto labor relationship. In order to safeguard the legitimate rights and interests of the applicant, the applicant hereby applies to your committee for confirmation of labor relations. Sincerely XXX Labor Arbitration Commission Applicant: Pan XX MM/DD/YYYY