Third person reply [1]
Interviewee: Fang? , female, 1963? Month? Date of birth, ID number: 440 1262449, address: Nansha District, Guangzhou? Road? Street? Number;
Interviewee: Lu? Male, 63 years old, Han nationality, from Huadu District, Guangzhou? Street? Avenue? No.1 new village? Dong? Room, ID number: 440121514, telephone number:1371903;
Request for defense: request to dismiss the respondent's claim according to law.
The respondent obtained the disputed house in this case in good faith (Address: Nansha District, Guangzhou? Avenue? Number? Building) ownership.
First, in this case, the respondent did not know whether the respondent had purchased the disputed house from the defendant before purchasing the disputed house from the defendant;
20XX March 12, respondent? After consultation, I signed a real estate sales contract with the defendant and bought a set of real estate under the defendant's name (property right number:).
Before buying a villa, respondents? I went to the real estate management department to inquire about the housing situation, and learned that only the defendant was registered as the owner in the real estate license, and I personally went to the disputed house in this case, and no one else lived.
Second, the respondent obtained the ownership of the disputed house in this case at a reasonable price;
May 8, 20XX, respondent? The defendant paid the house price of RMB 65,438+050,000, and the defendant also issued a formal invoice to the respondent, so the respondent obtained the ownership of the house in this case at a reasonable market price.
3. The Respondent and Defendant I are already fulfilling their respective contractual obligations and are going through the formalities of house registration and transfer;
On May 9th, 20XX, the Respondent and the Defendant submitted relevant materials to the Nansha District Real Estate Transaction Registration Center in Guangzhou, and applied for the transfer of the disputed house.
The above facts are evidenced by real estate sales contracts, invoices, real estate licenses and receipts from Nansha District Real Estate Transaction Registration Center.
Please ask the collegial panel to confirm it according to law.
According to the provisions of Article 106 of the Property Law, unless otherwise provided by law, the transferee shall acquire the ownership of real estate or chattel under any of the following circumstances:
The transferee is in good faith when accepting real estate or movable property;
(2) Transfer at a reasonable price;
(3) The transferred immovable property or movable property that should be registered according to law has been registered, and the transferred immovable property or movable property that does not need to be registered has been delivered to the transferee.
To sum up, when the respondent purchased the house, he didn't know whether the disputed house in this case had been purchased by others, and he paid a reasonable price, and was handling the house property certificate. Therefore, according to article 106 of China's Property Law, the house should be owned by the respondent.
Request the court to safeguard the legal rights of the respondent according to law and reject the respondent's claim.
Respondents:
20XX June 29th
The third person's reply [2]
The third person: XXX female, 46 years old, living at No.27, Longquan Village 1 Group, XXXX Township, Guangling District, Yangzhou City.
Plaintiff: XXX Address: Room XXXX, Oriental International Food City, Yangzhou.
Defendant: Yangzhou Human Resources and Social Security Bureau.
Address: No.746 Yang Zijiang Middle Road, Yangzhou.
Plaintiff XXX refuses to accept the decision made by Yangzhou Human Resources and Social Security Bureau? Yang Ren social worker Yanzi No. XXX (20 12) has brought a lawsuit to your hospital. As this specific administrative act has a direct interest with the third party, we hereby propose the following defenses:
1. The third party has no objection to the administrative reply given by Yangzhou Human Resources and Social Security Bureau.
Two, the third party has a labor relationship with the plaintiff, the facts are clear and the evidence is conclusive.
The plaintiff's claim that there is no labor relationship with the third party is inconsistent with the facts.
The plaintiff is distorting the facts and trying to get rid of his legal responsibility, and the plaintiff has failed to provide any evidence to prove that the labor relationship with the third party does not exist within the statutory time limit.
According to the Regulations on Work-related Injury Insurance, when employees disagree with the employer, the employer shall provide evidence.
On the contrary, the plaintiff in this case has proved the salary certificate of the third person working in his wholesale department (XX Liquor and Food Business Department in Guangling District).
This certificate fully shows that there is a labor relationship between the third party and the company operated by the plaintiff.
Three, Yangzhou City Human Resources and Social Security Bureau's work-related injury certificate found that the third person's work-related injury facts are clear, the evidence is conclusive, the applicable law is correct, the procedure is legal, and it should be maintained according to law.
(1)20XX At 8: 00 am on February 29th, 65438, while the third person was waiting for work, the company owner XXX (plaintiff) drove in front of the company and injured the third person. After the traffic accident, a large team of Yangzhou traffic patrol detachment made a traffic accident confirmation, and the plaintiff was fully responsible.
The injured part of the third person was diagnosed as medial collateral ligament injury of the right knee, anterior cruciate ligament injury of the right knee and soft tissue contusion of the right lower limb by Jiangsu Armed Police Corps.
According to paragraph 2 of Article 14 of the Regulations on Industrial Injury Insurance, those who are injured in the workplace due to violence and other accidents during working hours, and those who are injured by traffic accidents that are not the main responsibility on their way to and from work as stipulated in paragraph 6, shall be recognized as industrial injuries.
(2) A work-related injury certificate made by Yangzhou Human Resources and Social Security Bureau within the statutory time limit and scope and in accordance with legal procedures that the injury suffered by a third party is a work-related injury.
The administrative act procedure is legal and the applicable law is correct.
To sum up, the specific administrative acts identified by Yangzhou Human Resources and Social Security Bureau are clear in fact, correct in law and appropriate in procedure.
At the same time, in order to safeguard the dignity of the law and protect the legitimate interests of the weak, the court is requested to make a fair judgment according to law and reject the plaintiff's claim.
I am here to convey
Yangzhou Hanjiang District People's Court
Defendant: XXX
20XX 10 year1October 9th.
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