Defendant: male, born on, month, year, nationality, address: RoomNo.. Road, downtown. Contact information:
Requested items:
1. The defendant was ordered to pay RMB X to the plaintiff.
2. All litigation costs shall be borne by the defendant.
Facts and reasons:
The plaintiff and the defendant have a business cooperation relationship. The defendant owed money to the plaintiff, and by the end of 2005, the accumulated amount owed was RMB. However, when the repayment period expired, the defendant delayed repayment.
The plaintiff believes that the order contract relationship between the original defendant is legal and valid, and both parties should perform their contractual obligations in good faith. However, the defendant delayed the repayment of the arrears without justifiable reasons, which seriously damaged the legitimate rights and interests of the plaintiff and should bear the liability for breach of contract according to law. Accordingly, in order to safeguard the legitimate rights and interests of the plaintiff, we appeal to your hospital in accordance with the relevant provisions of the Contract Law of People's Republic of China (PRC) and the Civil Procedure Law of People's Republic of China (PRC). Please support the plaintiff's claim according to law.
Hereby!
dongguan municipal people's court
Prosecutor:
date month year
Attached:
1. X copies of this indictment (the number is determined according to the number of defendants);
Two, a copy of the evidence (with the contract as evidence);
Complaint of Arrears 2 Plaintiff: Zhang-,male, Han nationality,1born on May 5, 979, address: No.8-Street, Taishan District, Tai 'an City, and now lives in Room 402, Unit 2, Building 3, Daiyue District, Tai 'an City.
Defendant: Zheng, male, Han nationality, born on August 2, 196 1, now lives in Donghu Lake, second floor, East Unit of Tai 'an Dormitory, with the ID number of 370902 196 1080-
Defendant: Zheng, female, Han nationality,1born in August, 1967, now lives in Donghu dormitory on the second floor of Tai 'an East Unit, and her ID number is 370902 196708 17-
Defendant: Zheng, male, Han nationality, 1, born in September, 1985, now lives in Donghu, the second floor of East Unit of Tai 'an Dormitory, with ID number of 370902 1985090 1- Tel: 13438.
ask
1. Request the people's court to order the defendants Zheng and Zheng to repay the plaintiff's loan of 600,000 yuan immediately, and the defendant Zheng shall be jointly and severally liable for repayment.
2. The costs of litigation and preservation shall be borne by the two defendants.
Facts and reasons
On March 20xx 10, the defendants Zheng and Zheng borrowed 600,000 yuan from the plaintiff, and the agreed loan period was 2 months. If it is not returned at maturity, it will voluntarily pay the price of 93.08 square meters to Donghu Residence on the second floor of East Unit, South Building, Shopping Mall Lane with the defendant Zheng as the guarantor. There is written evidence to prove it. After the expiration of the time limit, the plaintiff repeatedly urged the defendant to refuse to perform the repayment obligation for various improper reasons. In order to safeguard the legitimate rights and interests of the plaintiff, we hereby file a lawsuit and request your hospital to make a judgment as soon as possible according to law.
I am here to convey
Taian Taishan District People's Court
Shaping people:
date month year
Part III Plaintiff: Zhang xx, male, Han nationality, born on, address: No.8, xx Street, Taishan District, Tai 'an City, and now lives in Room 402, Unit 2, Building 3, xx Community, Daiyue District, Tai 'an City.
Defendant: Zheng xx, male, Han nationality, born on, now living, ID number:
Defendant: Zheng xx, female, Han nationality, born on, now living, ID number:
Defendant: Zheng xx, male, Han nationality, born on, now living, ID number: telephone number.
ask
1. Request the people's court to order the defendants Zheng xx and Zheng xx to immediately repay the plaintiff's loan of 600,000 yuan, and the defendant Zheng xx shall be jointly and severally liable for repayment.
2. The costs of litigation and preservation shall be borne by the two defendants.
Facts and reasons:
On March 20xx 10, the defendants Zheng xx and Zheng xx borrowed 600,000 yuan from the plaintiff, and the agreed loan period was 2 months. If it is not returned at the due date, the defendant Zheng Xx will be the guarantor, and the price of 93.08 square meters of Donghu residence on the second floor of the East Unit of the South Building of Shangcheng Lane will be paid in one lump sum. There is written evidence to prove it. After the expiration of the time limit, the plaintiff repeatedly urged the defendant to refuse to perform the repayment obligation for various improper reasons. In order to safeguard the legitimate rights and interests of the plaintiff, we hereby file a lawsuit and request your hospital to make a judgment as soon as possible according to law.
I am here to convey
Taian Taishan District People's Court
Shaping people:
Xx year x month x day
Complaint of Arrears 4 Plaintiff: male, Han nationality, aged, ID number, now living in Yunlong District, Xuzhou City.
Plaintiff's telephone number:
Agent ad litem:
Telephone number of agent ad litem:
The first defendant: male, Han nationality, aged, ID number 320 # #, now living in tongshan district, Xuzhou, Tel:
Second defendant
Third defendant
Litigation request:
1. The plaintiff requested that the defendant be ordered to pay the plaintiff RMB according to law.
2. Request to order the defendant to pay RMB as liquidated damages for overdue payment.
The litigation costs in this case shall be borne by the defendant.
Facts and reasons:
The plaintiff and the defendant signed a contract for the purchase and sale of hardware fittings on February 5, 20xx 18, and then signed a contract for the purchase and sale of products (various lamps) on February 8, 20xx 18. In each contract, both parties agreed on the quantity, unit price, contract performance, payment method and time limit of lamps, and also agreed on liquidated damages. After the contract was signed, the plaintiff fulfilled the obligation of supplying and installing to the defendant in strict accordance with the contract. After the completion of the contract, after settlement by both parties, the actual total payment for hardware accessories is 13838, which was paid in advance at the time of signing the contract 19620 yuan, and still owed 12 18 yuan. The actual total price of the product purchase and sale contract is 1 17 184.2 yuan, and the advance payment is 12000 yuan. During the performance of the contract, 56,200 yuan was paid, and now 48,984.2 yuan is owed. That is, the total price of the two contracts is 224,022.2, and the defendant pays 87,820 yuan to the plaintiff, owing 136202. After the settlement between the two parties, the plaintiff repeatedly asked the defendant to pay the payment immediately according to the contract, but the defendant shirked the payment, which in fact constituted a breach of contract. According to the contract, the defendant shall bear the liability for breach of contract and pay the plaintiff a penalty of 67,206.6 yuan at 30% of the total contract price.
To sum up, the sales contract signed by the original and the defendant is the true intention of both parties and is legal and valid. The defendant owes the plaintiff RMB * *. The facts are clear and the evidence is sufficient. The creditor-debtor relationship between the two parties is clear, legal and effective and should be protected by law. Article 60 of the Contract Law stipulates: "The parties shall fully perform their obligations as agreed." And the first paragraph of Article 114 of the Contract Law stipulates: "The parties may agree that one party shall pay a certain amount of liquidated damages to the other party according to the breach of contract, or they may agree on the calculation method of the amount of damages for breach of contract." The defendant's non-repayment is a serious breach of contract, which damages the plaintiff's legitimate rights and interests and should bear the liability for breach of contract. The defendant shall pay the plaintiff overdue payment and liquidated damages of RMB * * *. In order to safeguard their legitimate rights and interests, the plaintiff had no choice but to bring a lawsuit to the people's court in accordance with the law, urging your court to order the defendant to pay the payment and liquidated damages owed by the plaintiff in accordance with the law and support the plaintiff's claim.
I am here to convey
Xuzhou people's court
Attached:
1, this complaint 1 copy.
2. A copy of the sales contract
3. A copy of the receipt
Prosecutor: Tel: MM DD YY.
Complaint of Arrears: xxx, male, born on ×××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××
Defendant: xxx, male, born on 19, with the nationality of ×××, and living in Room ×××,No. ××× Road, XX District, XX City. Contact information:
Requested items:
1. The defendant was ordered to pay RMB X to the plaintiff.
2. All litigation costs shall be borne by the defendant.
Facts and reasons:
The plaintiff and the defendant have a business cooperation relationship. The defendant owed money to the plaintiff until xx, xx, XX, and accumulated arrears of X yuan. However, upon the expiration of the repayment period, the defendant postponed repayment.
The plaintiff believes that the order contract relationship between the original defendant is legal and valid, and both parties should perform their contractual obligations in good faith. However, the defendant delayed the repayment of the arrears without justifiable reasons, which seriously damaged the legitimate rights and interests of the plaintiff and should bear the liability for breach of contract according to law. Accordingly, in order to safeguard the legitimate rights and interests of the plaintiff, we appeal to your hospital in accordance with the relevant provisions of the Contract Law of People's Republic of China (PRC) and the Civil Procedure Law of People's Republic of China (PRC). Please support the plaintiff's claim according to law.
Hereby!
Xx people's court
Prosecutor:
Xx，xx，XX，XX
Article 6 The plaintiff:
Domicile:
ID number:
Contact telephone number:
Defendant:
Domicile:
ID number:
Contact telephone number:
Litigation request:
1. Require the defendant to immediately return the plaintiff's loan of RMB18,000 yuan and interest (from March 20, 20xx to the court's judgment date, calculated at the bank's interest rate for similar loans in the same period).
2. In this case, the legal fees for requesting judgment shall be borne by the defendant.
3. Request that defendant II be jointly and severally liable.
Facts and reasons:
Defendant 1 borrowed RMB 55,000 from the plaintiff on xx, xx, XX, and wrote down the debit note. Defendant 1 promised to pay off the loan on March 20th, 20xx. After repeated collection by the plaintiff, the defendant repaid the loan of 17000 yuan, but refused to repay the remaining 18000 yuan. Defendant II, the' brother' of Defendant I, signed an agreement with the plaintiff and Defendant I on xx, xx, XX, stipulating that Defendant II would be the guarantor of Defendant I's loan.
To sum up, the plaintiff has no choice but to safeguard his legitimate rights and interests. According to the relevant laws and regulations, the plaintiff filed a lawsuit and asked the court to support the plaintiff's claim according to the facts.
I am here to convey
People's court
Shaping people:
_ _ _ _ _ _ _ _ _ _ _ _
Article 7 Plaintiff: Chu Ling, female, Han nationality, born on, and now living. Building _ _ _ _ East Street, Chaoyang District, Beijing, with the telephone number _ _ _ _.
Defendant: Han Qian, female, Han nationality, born on, and now living in Beijing First People's Hospital. Building, Gate _ _ _, Chaoyang District, Beijing, with the telephone number of _ _.
Cause of action: arrears dispute
Litigation request:
1. Request to order the defendant to return the arrears of 200,000 yuan and interest of 270 1 yuan, * * * 20270 1 yuan;
2. Request the defendant to bear the litigation costs.
Facts and reasons:
Defendant 20xx borrowed 200,000 yuan from the plaintiff on May 1 1 and promised to pay it off within three days. After the repayment period expired, the plaintiff demanded from the defendant many times, and the defendant refused to repay for various reasons. In order to protect the legitimate interests of the plaintiff from infringement, according to the provisions of Article 108 of the Civil Procedure Law of People's Republic of China (PRC), we hereby file a lawsuit in your hospital, requesting a judgment according to law.
I am here to convey
Chaoyang District People's Court
Shaping people:
Complaint of Arrears 8 Plaintiff: xxx, female, xx, xxxx, Han nationality, education level, work unit, position, address: _ _ _ _ _ _.
Defendant: xxx, male, xx, xx, Han nationality, technical secondary school, work unit, position and address: _ _ _ _ _ _.
Requested items:
1, and sentenced the defendant to repay the arrears of xxx yuan and interest of XXX yuan.
The defendant was sentenced to bear all the litigation costs of this case. Facts and reasons: On * *, 2000, the debtor * * * borrowed RMB 10,000 from the plaintiff, and wrote an iou to the plaintiff on the spot. However, after the repayment date, the defendant refused to repay the debt for various reasons and excuses, which seriously damaged the legitimate rights and interests of the plaintiff. We now appeal to the court to order the defendant XXX to repay the plaintiff XXX RMB X million and pay interest to safeguard the plaintiff's legitimate rights and interests.
I am here to convey
XXXX people's court
Plaintiffs: XXxXXXX, XX, XX, xx.
Attached:
1. X copies of this indictment (the number is determined according to the number of defendants);
Two, a copy of the evidence (IOUs as evidence);
Complaint for Arrears of Fees Article 9 Plaintiff: _ _ _ _ _, male, Han nationality, born on _ _, personal, address:No.: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
Defendant: _ _ _ _ _ _ _, male, Han nationality, born on _ _, personal, living in. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Request: 1. The defendant was ordered to repay the arrears of RMB _ _ _ _ and the corresponding interest according to law.
The defendant should bear the legal costs of this case.
Facts and reasons: The plaintiff and the defendant had done _ _ _ _ _ business. On, the defendant owed the plaintiff RMB _ _ _ _ _ _ _ _ _ _ _ ten thousand yuan, and issued an iou. The plaintiff repeatedly asked the defendant to repay, and the defendant promised to repay, but the defendant did not take action. The plaintiff had no choice but to entrust a lawyer to urge the defendant to pay the debt, and the defendant returned _ _ _ _ yuan in cash one after another, and counted _ _ _ _ _ yuan as * * *, but still owed _ _ _ _ yuan.
Therefore, in order to safeguard the legitimate rights and interests of the plaintiff, according to the provisions of Article 28 of the Civil Procedure Law, we hereby file a lawsuit and request to support the plaintiff's claim according to law.
I am here to convey
People's court
Shaping people:
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Complaint of Arrears 10 Appellant, male, 43 years old, Han nationality, Wuhai, self-employed, now living in Chabu Gypsum Industrial Park, contact information: 13904737696.
Appellee: Ordos Chuangyuan Road and Bridge Engineering Co., Ltd., with the domicile of No.6, Baodi Taohai East Street, Dongsheng District.
Legal representative: Su Huaizhong, general manager, contact information: 13294899798 The appellant refused to accept the civil judgment (20xx) No.286 of the People's Court of Otog Banner, Inner Mongolia, and filed an appeal according to law.
Litigation request:
1. Revoke the civil judgment (20xx) No.286 of the People's Court of Otog Banner, Inner Mongolia;
2. Reject the appellee's claim;
3. The costs of the first and second trial of this case shall be borne by the defendant.
Facts and reasons
The facts of the original judgment were unclear, and the applicable law was wrong, so it was requested to change the judgment according to law.
First, the appellant's behavior is a serious infringement, and the fact was unclear in the original judgment for the following reasons:
1. According to the spirit of two documents, Minutes of the Meeting of the People's Government of Otog Banner on Establishing the Chabu Industrial Development Zone (No.20x3) and Decision of the People's Government of Otog Banner of China on Establishing the Chabu Gypsum Industrial Development Zone in Otog Banner of Inner Mongolia (No.20x14), the appellant.
Enterprises that process and sell gypsum and pay relevant land use fees (such as land and levy fees) also apply for industrial and commercial business licenses according to law. Counterclaim built two factories in his own land, and the whole field was surrounded by walls.
For this fact, even if the appellant mentioned it many times in the trial and produced evidence such as notarial certificate and business license to prove it, the original judgment also recognized the validity of notarial certificate, but why didn't the original judgment review the appellant's property ownership? The fact that the original judgment should confirm that the destroyed property belongs to the appellant has not been confirmed, and it belongs to unclear facts.
2. On October 2, 20xx/kloc-0, 10, the appellee forcibly pushed down the appellant's fence with a vehicle without the appellant's knowledge, resulting in all damages to the appellant's factory and property, with economic losses of/kloc-0 1497463.75 yuan. The appellant reported the case to the police that day to protect the property.
For this fact, the original judgment should find out the reasons why the appellee pushed down the appellant's fence and demolished the appellant's warehouse according to law. The appellee argued that there was a so-called construction contract, and the court of first instance should also find out the positioning, scope and scope of the appellee's construction contract. Without finding out the facts of these cases, how did the original judgment confirm that the appellee's so-called construction contract included the appellant's factory? In the original judgment, it was only the fact that the appellant seized the appellee's machine that the appellee violated the appellant's property legally, which was quite different from the objective facts of this case.
Third, the original judgment rejected the appellant's report materials on the grounds that "it was not identified, the situation was unclear and the plaintiff did not recognize it". First of all, the appellant did not accept the original judgment.
Objection to the court's decision. Did the appellee put forward the appraisal of evidence materials, or did the court of first instance think it necessary to put forward the appraisal according to its functions and powers, but the appellee did not put forward the appraisal, so the court of first instance had no authority to take the initiative to conduct the appraisal. Is it that the appellant himself proposed to appraise the evidence submitted by him? Secondly, the evidence was reported by the appellant when the appellee destroyed the appellant's property. Does the appellant dare to report a false case? With regard to the probative force and size of evidence, according to Article 64 of the Supreme People's Court's Provisions on Evidence in Civil Proceedings (hereinafter referred to as the "Provisions on Evidence"), the judge should comprehensively and objectively examine the evidence in accordance with legal procedures and make an opposite judgment, and shall not decide whether to adopt the evidence on the grounds of whether the plaintiff approves it or not. Moreover, according to the provisions of Items (2) and (3) of Article 70 of the Evidence Regulations, the judgment of first instance shall be recognized.
Second, the application of law in the original judgment was wrong.
First, according to the first paragraph of Article 13 of the Constitution of People's Republic of China (PRC) and Article 66 of the Property Law of People's Republic of China (PRC), the legal property owned by citizens privately is inviolable and protected by law, and it is forbidden for any unit or individual to destroy it. The court of first instance held that the property legally possessed by the possessor was protected by law. Isn't the property legally owned by the owner not protected by law? Possession belongs to usufructuary right, and ownership belongs to complete property right.
Second, it is a typical act of self-defense for the appellant to call the police and seize his illegally infringed tools and hand them over to the police. According to the provisions of Articles 3 and 4 of the Tort Liability Law of People's Republic of China (PRC), whether the public security department files a case does not affect the appellee's liability for its tort.
Thirdly, it is a serious legal mistake that the original judgment takes Article 245 of the Property Law as the legal basis, because the original judgment does not clearly stipulate which clause of the law applies, and the legal basis of detailed legal provisions, paragraphs and items should not be used as the basis of the judgment. In addition, if the original judgment holds that the appellant's behavior belongs to the occupation of real estate or movable property, then this situation obviously does not exist. If the original judgment considers that the appellant's behavior is an obstruction to the possessor's possession, then according to the original legislative intent, the appellant thinks that the legitimate defense of the possessor's possession is not an obstruction to possession, but a legitimate remedy for the infringement of the appellant's property ownership by possession, which is a legitimate act to stop the illegal infringement from continuing. Therefore, it is wrong to apply this law to the original judgment.
To sum up, the judgment of the court of first instance found the facts unclear, applied the law wrongly, ignored the objective fact that the appellant's legal property ownership was illegally infringed by the appellee, and ignored the property losses caused by the appellee, thus making a wrong judgment. In order to safeguard the appellant's legitimate rights and interests, we hereby appeal to your hospital according to law, and hope that the judgment will be as requested.
This demonstration
Inner Mongolia Ordos Intermediate People's Court
20xx.x.x
Complaint of arrears 1 1 Plaintiff: XXX, female, 1978 February 18, Han nationality, primary school culture, individual, address: _ _ _ _ _ _ _ _ _.
Defendant: XXX, male, 1980 0 19 year 10 month 19, Han nationality, technical secondary school, work unit: _ _ _ _ _ _, occupation: _ _ _ _ _, address: _ _.
Requested items:
1, and sentenced the defendant to repay the arrears of 90,000 yuan;
The defendant was sentenced to bear all the litigation costs of this case.
Facts and reasons:
On * *, 2000, the original debtor * * transferred the debt of RMB 90,000 yuan owed to the plaintiff to the defendant, and the defendant agreed to bear it, and issued an iou to the plaintiff on the spot. The plaintiff also agreed. However, the defendant used various reasons to borrow money.
The delay in paying off the debt has seriously damaged the plaintiff's legitimate rights and interests.
I am here to convey
XXXX people's court
Plaintiff: xxx
XXXX year x month XX day
Complaint of Arrears 12 Plaintiff: (name), (gender), year, month, Han nationality, education level, work unit, position and address:
Defendant: (name), (gender), MM DD YY, MM DD YY, Han nationality, education level, work unit, position and address:
Requested items:
1, and sentenced the defendant to repay the arrears of xxx yuan and interest of xxx yuan.
The defendant was sentenced to bear all the litigation costs of this case.
Facts and reasons:
On xx, XX, XX, the debtor xxx borrowed RMB X million from the plaintiff and issued an IOU to the plaintiff on the spot. However, after the repayment date, the defendant refused to repay the debt for various reasons and excuses, which seriously damaged the legitimate rights and interests of the plaintiff.
We now appeal to the court to order the defendant xxx to repay the plaintiff xxx RMB X million and pay interest to safeguard the plaintiff's legitimate rights and interests.
I am here to convey
Xxxx people's court.
Plaintiff: xxx
20xx x month xx day
Complaint of Arrears 13 Plaintiff: Chen xx, male, Han nationality, born on April 1 1 day, X, and living in xx, Building X, Kangyiju, Dongtai Garden, Dongcheng District, XX Province.
Authorized Agent: lawyer of Zeng xx, xxxx Law Firm.
Defendant: Huang xx, the owner of the textile processing factory of xx enterprise, lives at xx Road, xx Village, xx Town, XX City, and the telephone number is xxxxxxxxxxxxx.
Requested items:
1. ordered the defendant to pay the plaintiff RMB 9,225.2;
2. The defendant is ordered to pay the plaintiff the interest on the payment in arrears until the date when the payment is fully paid off, and the interest is temporarily calculated according to RMB 169 yuan until the date of prosecution (the interest rate is calculated according to the loan interest rate of financial institutions for the same period stipulated by the People's Bank of China);
Third, the defendant was ordered to bear the litigation costs of this case.
Facts and reasons
During July and August of xxxx, the plaintiff carried out business activities with the defendant in the name of xx John Wan Paper Tube Factory (without industrial and commercial registration). The plaintiff * * * sold paper tubes with a total value of 9225.2 yuan to the defendant, and the defendant received all the goods sold by the plaintiff in full. The two sides verbally agreed that the loan would be repaid. The plaintiff repeatedly asked the defendant to pay in time, but up to now, the defendant has no obligation to pay.
In order to protect their legitimate rights and interests, the plaintiff is now suing your hospital. Please find out the facts and make a ruling as required.
I am here to convey
Xx Municipal People's Court
Plaintiff:
Authorized Agent: lawyer of Zeng xx, xxxx Law Firm.
Xxxx year month day
Complaint of Arrears 14 Plaintiff XXX, male, born on XX, XX.
Defendant ×××, female, was born on ×××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××
Requested items:
1. Request the court to order the defendant to pay the plaintiff RMB xxxxxx (in words: XXXXXX);
2. Request the court to order the defendant to pay the interest xxxxxx owed by the plaintiff;
All litigation costs shall be borne by the defendant.
Facts and reasons:
The plaintiff and the defendant are relatives (friends/colleagues/××). As of {\ \ F6527 \ \ F6527 \ \ F6527 \ \ F6527 \ \ F6527 \ \ F6527 \ \ F6527 \ \ \ F6527 \ \ \ \ \ \ \ \ \ \ \ \ \ \ \\ \\ \\ \\ \
The plaintiff believes that the loan contract relationship between the original defendant is legal and valid, and both parties should perform their contractual obligations in good faith. However, the defendant refuses to return the arrears without justifiable reasons and should bear the liability for breach of contract according to law. Accordingly, in order to safeguard the legitimate rights and interests of the plaintiff, we appeal to your hospital in accordance with the relevant provisions of the Contract Law of People's Republic of China (PRC) and the Civil Procedure Law of People's Republic of China (PRC). Please support the plaintiff's claim according to law.
I am here to convey
Xx people's court of xx city
Prosecutor: xxx
* * * Year * * Month * * Day