Plaintiff: Yao xx, male, Han nationality,/kloc-0, born on xx, xx, and living in Room xx, Building xx, xx Road, xx District, xx City.
Plaintiff: Tang xx, female, Han nationality, 19xx, born on xx, and living in Room xx, Building xx, xx Road, xx District, xx City.
Plaintiff's address: Room xxxx, XX Building,No. XX Road, Ning, XX City.
Postal code: xxxx phone number: xxxx
Defendant Yu xx, female, Han nationality, 19xx was born on xx, xx, and lives in Room xx, Building xx, xx Road, xx District, xx City.
Defendant Yu xx, male, Han nationality, was born on X, X, and lives in Room xx, Building xx, xx Road, xx District, xx City.
Postal code: xxxx phone number: xxxx
Litigation request:
1. ordered the second defendant to pay the plaintiff a penalty of RMB 35, 680 yuan only;
The legal costs shall be borne by the two defendants.
Facts and reasons:
20xx65438+On February 5th, the plaintiff and the defendant signed the xx Real Estate Purchase and Sales Contract under the mediation of xxx Housing Service Co., Ltd., and the contract stipulated that the plaintiff (namely Party B) would purchase the house owned by the defendant (namely Party A) in Room xx, Building xx, xx Road, xx District, xx City, with a house price of RMB X million only. On the day of signing the contract, the two parties signed a compensation agreement, stipulating that Party B will pay Party A an additional compensation of xx million yuan for decoration and equipment. The plaintiff only paid RMB 50,000 to the defendant on the day when the contract was signed; Pay the defendant RMB 2.74 million only in 20xx65438+February 65438+March. According to the supplementary terms of this sales contract, Party A shall deliver the house to Party B within 3 working days after receiving the loan from Party B (RMB 2.9 million only), with the delivery sign that Party A will deliver the house key to Party B and settle the property management fee, water, electricity, gas (if any), telephone (if any), cable TV (if any) and other expenses.
At the same time, this sales contract stipulates that Party B will directly pay Party A the house price of 654.38+00,000 yuan only on the day when both parties complete the house handover procedures. 20xx On February 3rd, the plaintiff's loan bank, Agricultural Bank, lent the defendant RMB 2.9 million. According to the sales contract, the defendant should deliver the house to the plaintiff within 3 working days, that is, February 8, 20xx. The defendant delayed the delivery of the house until February 2, 20xx1day (* * * 13) for some reason, and the original and the defendant signed the house purchase and sales handover letter to complete the delivery procedures, and the plaintiff paid the defendant the balance of10,000 yuan.
Based on the above facts, the plaintiff believes that the house sales contract signed by the original and the defendant is a true expression of will and should be legal and effective. The defendant's failure to deliver the house on time as agreed in the contract constitutes a breach of contract. According to this contract, if Party A fails to deliver the above-mentioned real estate (including real estate handover and transfer of real estate rights) to Party B within the time limit agreed in this contract, it shall pay Party B liquidated damages calculated at 0.5 ‰ of the payment date of Party B, from the due delivery date agreed in this contract to the actual delivery date. The defendant delayed the delivery of the house for 13 days, totaling RMB 37,050. After deducting the liquidated damages of 1 day from the plaintiff's overdue payment 1 yuan and 370 yuan, the defendant shall pay the plaintiff a liquidated damages of 35,500 yuan. Here, please make a judgment in accordance with the law.
I am here to convey
Xx District People's Court of xx City
Tangible person: xxx
X year x month x day
Complaint of sales dispute 2 Plaintiff: _ _ _ _ _ _ _ _ _ _ _ _ Co., Ltd.
Address:No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Legal Representative: _ _ _ _ _ _ _ Title: Chairman/General Manager
Defendant: _ _ _ _ _ _ _ _ _ _ _ _ _ _ Co., Ltd.
Address:No. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Legal Representative: _ _ _ _ _ _ _ _ _ _ _ _
Position: Chairman/General Manager
Tel: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Defendant: _ _ _ _ _ _ _, male, Han nationality, born on.
Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Tel: _ _ _ _ _ _ _ _ _ _ _
ask
1. Request to order the defendant to pay _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ to the plaintiff;
2. Ask the defendant to pay a penalty of RMB _ _ _ _ _ _ _ _ _.
3. Request the defendant to bear all the litigation costs of this case.
Facts and reasons:
On a certain day in _ _ _ _ _ _ _ _
Therefore, in order to safeguard their legitimate rights and interests, we hereby file a lawsuit with your hospital, hoping to support it.
I am here to convey
_ _ _ _ _ _ _ _ _ People's Court
Tangible person: _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Complaint of sales dispute 3 Plaintiff:
Domicile:
Legal Representative: Position:
Defendant:
Domicile:
Legal Representative: Position:
Cause of action: dispute over the arrears of the sales contract.
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 signed a purchase and sale contract with the defendant on, with the plaintiff as the supplier, the defendant as the buyer, and the supplier providing the model for the buyer. According to the contract, the name, specification, price and quantity of the goods are the total payment.
Payment method:; If the buyer is late in payment, the buyer shall pay the seller a late fee according to the payment receivable for each day overdue. After the contract was signed, the defendant failed to perform his obligations as agreed in the contract. The plaintiff began to default on the payment for goods on, and in order to maintain the friendly and cooperative relationship between the two parties, the plaintiff still delivered the goods to the defendant company as scheduled according to the defendant's order. The defendant defaulted on the plaintiff's goods every month.
The payment method is as follows: year, month and day, RMB yuan; Year, month, RMB yuan; Year, month and year, RMB yuan; The above amounts to RMB yuan. The plaintiff repeatedly asked the defendant to pay the above amount, but the defendant refused to pay for various reasons. 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 RMB * * to the plaintiff, and the facts are clear and the evidence is sufficient, so it can be determined; Creditor's rights and debts of both parties
Clear, legal and effective, 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 failure to repay the purchase price is a serious breach of contract, which seriously damages the legitimate rights and interests of the plaintiff and should bear the liability for breach of contract. The defendant shall pay the plaintiff a penalty of RMB * * * for late payment. The plaintiff's claim has both factual evidence and legal basis, and the people's court supports it. In order to safeguard their legitimate rights and interests, the plaintiff brought a lawsuit to your hospital in accordance with the provisions of Article 108 of the Civil Procedure Law of People's Republic of China (PRC), and urged your hospital to support it after finding out the facts.
I am here to convey
Attached:
1, copy of this certificate
2. Written proof
3. Other materials: legal representative: year, month and day.
Complaint of sales dispute 4 Plaintiff: name, gender, date of birth, nationality, education level, native place, work unit, address, ID number and contact number;
Defendant: name, gender, date of birth, nationality, education level, native place, work unit, address, ID number and telephone number;
Litigation request:
1. Request your court to order the defendant to continue to perform the contract, and order the defendant to unconditionally deliver the plaintiff's house for legal procedures.
2. We request your court to order the defendant to pay RMB ××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××
The plaintiff requested to increase the amount of liquidated damages on the grounds that the agreed liquidated damages were lower than the losses caused. It is required to pay compensation to the plaintiff according to the building of 22 yuan/month/square meter, in RMB * * * (in words:).
Four. Request your court to order the defendant to pay the plaintiff a penalty of RMB ××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××
Verb (abbreviation of verb) requests your court to order that all relevant expenses of this case, including legal fees, shall be borne by the defendant.
Facts and reasons
The plaintiff and the defendant are parties to the commercial housing sales contract. The plaintiff signed the Commercial House Sales Contract with the defendant on ××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××× The rights and obligations between the original defendant and the defendant are stipulated in detail in the contract. The plaintiff paid the down payment of RMB ××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××× However, the defendant failed to legally obtain the Permit for Delivery and Use of Residential Commercial Houses in accordance with the Regulations of Tianjin Municipality on the Administration of Commercial Houses, which led to the plaintiff's failure to legally move in on 20 101October 20. According to the first paragraph of Article 5 of this contract, "Party A shall pay the paid interest to Party B, and the interest shall be calculated at the bank loan interest rate for the same period from the day after Party A delivers the commercial houses as agreed in this contract to the actual delivery date of the commercial houses.
According to Article 16 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Laws in the Trial of Disputes over Commercial Housing Sales Contracts, if the parties request an increase on the grounds that the agreed liquidated damages are lower than the losses caused, the amount of liquidated damages shall be determined according to the losses caused by breach of contract; Article 17 Compensation standard for losses: If the house is delivered for use after the deadline, it shall be determined according to the rent standard for similar houses in the same lot published by the relevant competent authorities or assessed by qualified real estate appraisal agencies during the overdue delivery period. According to the Notice of Tianjin Municipal Bureau of Land Resources and Housing Administration on Issuing the Guidance Rent of 20xx Housing Leasing Market, the guidance rent of 20xx residential housing in Hongqiao District 06-05 22 yuan/month/building square meter in Shaogongzhuang New District is requested to increase the amount of liquidated damages on this basis. 20xx 10 to June 20xx 10, the liquidated damages are RMB ××××××.
The plaintiff repeatedly asked the defendant to pay interest and liquidated damages according to the contract, but all reasonable demands were rejected. The defendant deliberately evaded the plaintiff's inquiry. In desperation, the plaintiff had to take up legal weapons to safeguard his legitimate rights and interests. Now, according to the relevant provisions of the Contract Law of People's Republic of China (PRC) and the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Laws in the Trial of Commercial Housing Contract Disputes, we filed a lawsuit in your hospital on June 20xx 1, requesting the people's court to support it according to law.
Evidence and sources of evidence, names and addresses of witnesses
I am here to convey
Xxxx people's court
Attachment: 1 Copy of the indictment × (submitted according to the number of defendants);
2.x pieces of evidence.
Metaphor: ×××××
X year x month x day
Plaintiff 5: Male, Han nationality, aged, ID number, now living in Yunlong District, Xuzhou City.
The 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.
Complaints about sales disputes 6 special lawyers
E-mail: [E-mail protected]
Plaintiff: XX sex: male date of birth:1993165438+1October 9 nationality: legal representative of Han nationality: XX sex: female date of birth:19681nationality:
Defendant: XXX Sex: Female Date of Birth: March 23rd Nationality: Han Nationality Address: A, XX Street, Xicheng District, Beijing
Litigation request:
1. Request the court to order the defendant to fulfill his promise according to law, and complete the relevant property transfer procedures with the plaintiff * * *;
2. Request the court to order the defendant to compensate the plaintiff RMB 10000 Yuan only;
3. The litigation costs and related expenses in this case shall be borne by the defendant.
Facts and reasons:
20xx65438+1On October 24th, the plaintiff and the defendant signed a second-hand house sales contract. Both parties agreed that the plaintiff purchased a second-hand house from the defendant (located in. /kloc-floor x of dormitory building 0/0. In Xiaoxitian XXXXX, Xicheng District, Beijing, the defendant promised to complete the house with the plaintiff.
Relevant procedures of property right transfer. The price of this house is 250 thousand yuan. The plaintiff paid a deposit of 5,000 yuan to the defendant on October 22nd, 20xx/kloc-0, and the balance of 245,000 yuan was paid to the defendant on October 24th, 20xx/kloc-0, 65438. After receiving the house payment, the defendant delivered the house ownership certificate to the plaintiff at Room X, Floor X, No.XX Dormitory Building, XX Street. Up to now, the defendant and the plaintiff have made slow progress in handling the relevant formalities of property transfer, which has caused economic losses to the plaintiff.
According to the above facts, the plaintiff sued the court, requesting the court to order the defendant and the plaintiff * * * to complete the relevant property transfer procedures, and compensate the loss of 10000 yuan and bear the litigation costs of this case.
I am here to convey
Xicheng District People's Court of Beijing Municipality
Pledgee (plaintiff): XXX
20xx 65438+ 10 month 14
Complaint No.7: Plaintiff: * * *, male, Han nationality, born on * *, ID card address: * * *, ID card number: * * *, operator of * * *.
Defendant 1: * * *, male, Han nationality, born on * *, ID card address: * * * *, ID card number: * * * *.
Defendant 2: * * *, female, Han nationality, born on * * * on * * year, ID address: * * *, ID number: * * *.
The current addresses of the two defendants are * * * *.
Cause of action: sales contract dispute
Litigation request:
1. Please adjudge the two defendants to pay RMB * * * yuan (* ten thousand * * yuan only) according to law, and the two defendants shall be jointly and severally liable for the arrears.
2. Please order the two defendants to pay the overdue loan interest according to the standards of financial institutions stipulated by the People's Bank of China from the date of prosecution until the two defendants pay off all the debts.
3. All litigation costs in this case shall be borne by the two defendants.
Facts and reasons:
The plaintiff started to run the trade department in * * in 20xx, and the defendants * * and * * were also two couples who were engaged in decoration business in * * town. They began to buy commercial housing in * * in 20xx. They have often bought glass products from the plaintiff for many years, and they owe * * * yuan for the goods. Defendant * * wrote an "IOU" on February 20th, 20xx65438 to confirm the above-mentioned arrears.
The two defendants are husband and wife and do business together in a family-run mode. * * * Both of them bought glass products from the plaintiff, and they should be the obligatory subjects of the arrears. And the two defendants have no other occupations, and all their business income is used for family life, so the two defendants should be jointly and severally liable for the money owed.
Now the plaintiff has repeatedly urged the two defendants to repay, but the two defendants have been in arrears. In order to safeguard their legitimate rights and interests, the plaintiff filed a lawsuit with your hospital, requesting your hospital to support the plaintiff's claim according to law.
I am here to convey
* * City First People's Court
Shaping people:
date month year
Complaint for sales dispute 8 Plaintiff: Name: _ _ _ Gender: _ _ _ Age: _ _ _ Nationality: _ _ _ Position: _ _ _ _ _ _
Work unit: _ _ _ _ _ _ Address: _ _ _ _ _ _ Tel: _ _ _ _ _ _ _
Defendant: Name: _ _ _ _ _ Address: _ _ _ _ _ _ _
Legal Representative: Name: _ _ _ _ _ Title: _ _ _ _ _ _
Tel: _ _ _ _
Litigation request:
1. Request the defendant to pay the plaintiff remuneration and interest of RMB.
2. The litigation costs in this case shall be borne by the defendant.
Facts and reasons:
Starting from _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Therefore, according to Article _ _ of the General Principles of Civil Law, we hereby file a lawsuit in your hospital to support the plaintiff's claim and safeguard the plaintiff's legitimate rights and interests.
I am here to convey
_ _ _ _ _ _ _ _ _ _ _ _ People's Court
Tangible person: _ _ _ _ _ _ _
Complaint of sales dispute 9 Plaintiff:
Defendant:
ask
1. Please order the defendant to pay the principal of one million yuan only (￥ 1000 000.00 yuan).
2. Pay overdue interest (calculated according to the bank loan interest rate standard for the same period).
The litigation costs of this case shall be borne by the defendant.
Facts and reasons
Defendant XXX gave me an IOU of RMB 10000000 on, and agreed that the repayment date was, on, and on. After the expiration, I asked the defendant for it many times. The defendant refused to repay the loan for various reasons, and appealed to the people's court, requesting that the defendant be ordered to pay the outstanding principal of 65,438+0,000,000.00 yuan and pay the overdue interest (calculated according to the bank's loan interest rate standard for the same period). The legal costs of this case shall be borne by the defendant.
I am here to convey
A people's court
Attachment: copy of plaintiff's ID card.
A copy of the iou.
Prosecutor:
date month year
Complaint of sales dispute 10 Plaintiff: female, Han nationality, 1942 was born on May 9.
ID number:
Address: Panyu Road, Changning District, Shanghai
Telephone:
Defendant 1: Taicang Carnival Real Estate Development Co., Ltd.
Address: No.26 Dangqian Road, Huangjing Town, Taicang City
Legal Representative: Rebecca.
Contact telephone number:
Defendant 2: Shanghai Dong Rui Building Decoration Engineering Co., Ltd.
Address: Room 403, No.270 Dezhou Road, Pudong New Area, Shanghai.
Legal Representative: Ni Zhenhua
Tel: 02 1-68328820
Claim: 1. The two defendants were ordered to immediately pay the plaintiff's house refusal fee and decoration fee of 394,588 yuan.
2. The two defendants were ordered to pay the plaintiff interest of * * * 6050 yuan (from the overdue date, the interest will be temporarily calculated according to the bank's loan interest rate standard for the same period until 20x65438+February 20 until the effective date of the judgment).
The two defendants were sentenced to bear the legal costs of this case.
Facts and reasons:
On July 9, 20xx, the plaintiff and defendant I signed a commercial housing sales contract with the number of 201317100024, stipulating that the plaintiff would purchase the house located at Room 608, Building 2, Tongming Times Home, No.26 Dangqian Road, Huangjing Town, Taicang City. The total house price is RMB yuan, and the delivery date is years ago. In addition, Defendant II (an affiliated company of Defendant I) also signed a renovation contract with the plaintiff, stipulating that Defendant II would purchase the house involved for renovation, with a total renovation price of RMB.
After the contract was signed, the plaintiff paid all the money under the contract to the two defendants in accordance with the contract. Later, due to the defendant's late delivery, the plaintiff signed a check-out agreement and a refund agreement with the two defendants. According to the agreement, the two defendants dissolved the house purchase contract and renovation contract with the plaintiff, and returned the house purchase price, compensation and decoration payment totaling 394,588 yuan to the plaintiff before August 20, 20xx (including house purchase price of 365,438 yuan+09,876 yuan, compensation of 65,438 yuan+08,790 yuan and decoration payment of 55,922 yuan). At present, the two defendants have been delaying payment, and the plaintiff's repeated requests for payment have been rejected by the two defendants.
To sum up, after the plaintiff and the two defendants reached an agreement to return the house and refund the decoration fee, the plaintiff and the two defendants fulfilled the relevant procedures required to terminate the contract according to the agreement, and the two defendants delayed the payment obligation without reason, which was a serious breach of contract and constituted a malicious breach of contract. In order to protect their legitimate rights and interests in accordance with the law, the plaintiff filed a complaint with your hospital, hoping that your hospital would protect the plaintiff's legitimate rights and interests in accordance with the law and order the two defendants to immediately pay the plaintiff's purchase price, decoration price and interest incurred during the delay.
I am here to convey
Taicang people's court
Shaping people:
date month year