1, header:

(1) topic, writing a civil complaint;

(2) The basic information of the parties includes the name, gender, age, nationality, occupation, work unit and domicile of the plaintiff and defendant, the name and domicile of the legal person or other organization, and the name and position of the legal representative or principal responsible person. If a third party participates in the lawsuit, the name and basic information of the third party shall be stated after listing the parties, and the relationship between the third party and the original defendant shall be stated according to the needs of the case;

2. Contents:

(1) The matters requested in the litigation request must be clearly and specifically written, and cannot be vague and abstract;

(2) Facts and reasons should focus on the purpose of litigation and fully reflect the objective and true situation of the facts of the case. To complete the narrative, we should explain the six elements of the facts of civil cases, namely, time, place, person, thing, cause and effect. The narrative should be true. The indictment is one of the important bases for the court to accept the case. When describing the case, we must seek truth from facts and reflect the original appearance of the case facts. The narrative should be clear. Facts that are directly related to the disputed facts should be described in detail, and those that are not important to the facts of the case can be briefly summarized but must be clearly explained. Use words accurately and express facts appropriately. The reason part mainly lists the evidence and explains the source of the evidence, the name and address of the witness; According to the facts and the relevant provisions of the law, conduct rational argumentation. In the facts and reasons, the process of signing the contract, the specific content, the cause of the dispute, the litigation request and the relevant legal and policy basis should be stated.

(3) Evidence and its sources, names and addresses of witnesses. The name, number, source or clue of the evidence shall be clearly stated. If there is a witness, the name and address of the witness shall be stated.

3. The tail and the appendix include the name sent to the people's court; Signature of the holder; Time of prosecution. The annex shall mainly indicate the contents and copies of the materials, including copies of the complaint, physical evidence and documentary evidence.

Attached model: civil appeal model of private lending

Complaints about private lending

Plaintiff: Li xx, male, Han nationality, born on xx 19xx, living at xx Meizhou North Road, xx Town, xx District, with ID number XX 03211972091570xx and mobile phone number 1384 88668.

Defendant Xu xx, male, Han nationality, 19xx, was born on xx, xx, and lives in. ××× District×× Village Lidou×××, ID number ×× 03211973061566xx.

Litigation request:

1. Order the defendant to repay the plaintiff's loan principal1153,000 yuan;

2. From June 25, 2009, 65438+20091October 25, interest shall be calculated at four times the interest rate of similar loans from banks until the defendant pays off the principal and interest; (The interest temporarily calculated to the date of prosecution is 487,765,438 yuan+09);

The legal costs of this case shall be borne by the defendant.

Facts and reasons:

The defendant Xu xx borrowed from the plaintiff Li xx twice, totaling RMB1153,000 yuan, due to the difficulty in capital turnover. On June 22, 2008, the plaintiff borrowed 928,000 yuan for the first time and 65,438 yuan+365,438 yuan for the second time. Defendant Xu xx issued two "IOUs", in which both parties agreed that "if the payment cannot be made on June 25th, 2009, the borrower is willing to pay the liquidated damages1.4 every day"; According to "Several Opinions of the Supreme People's Court on the Trial of Lending Cases", the interest rate of private lending can be appropriately higher than the bank interest rate, but the maximum interest rate shall not exceed 4 times that of similar loans of banks; The two sides agreed on the IOU that the plaintiff did not advocate the so-called "liquidated damages", that is, the interest was more than four times that of similar bank loans. In June 2009, the annual interest rate of two-year loans of commercial banks was 5.40%. The interest was calculated from June 25, 2009 to the date of prosecution, and the provisional interest was 487,765,438 yuan +09. The plaintiff urged the defendant many times, and the defendant has not returned a penny so far; In order to protect the legitimate rights and interests of the plaintiff, we hereby file a lawsuit with your hospital, and hope that the judgment will be as it wishes!

I am here to convey

Xx District People's Court

Tangible person: xxx

Date, year and month

Legal basis: Article 122 of the Civil Procedure Law of People's Republic of China (PRC), prosecution must meet the following conditions:

(1) The plaintiff is a citizen, legal person and other organization that has a direct interest in the case;

(2) Having a clear defendant;

(3) Having specific requests, facts and reasons;

(4) It falls within the scope of civil litigation accepted by the people's court and is under the jurisdiction of the sued people's court.