Civil action for arrears

The case of default dispute is one of the most common disputes in China, which is usually solved through civil litigation. The following is the civil complaint of arrears that I have compiled, hoping to help everyone.

Article 1 of civil complaint of arrears Plaintiff:

Defendant:

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.

Civil Complaint of Arrears 2 Plaintiff:

Defendant:

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 the loan is not repaid at maturity, the defendant Zheng xx will be the guarantor to pay Zhang Yong a one-time payment of 93.08 square meters for the East Lake on the second floor of the south building of the dormitory.

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.

Civil Complaint of Arrears Article 3 The plaintiff:

Defendant:

ask

1. Insist on divorcing the defendant;

Second, the legitimate daughter Mei belongs to the plaintiff's custody, and the defendant pays the maintenance fee in one lump sum;

Third, according to the division of husband and wife property;

Facts and reasons

I was introduced to the defendant in xx and got married in xx. May, an illegitimate daughter, was born on October 28th, 65438/kloc-0. She is now studying in a middle school in Fuxin.

At the beginning of our marriage, I had a good relationship with the defendant. After half a year of marriage, the two sides often quarreled because of personality reasons and trivial matters in life, and the plaintiff was beaten and scolded by the defendant many times. Therefore, I sued for divorce in 20xx 165438+ 10, and the case was concluded by the court in 20xx 65438+February. Since then, I have been separated from the defendant for 42 months, and the relationship between the two sides has not improved.

The above facts are enough to show that our relationship has indeed broken down and the relationship between husband and wife exists in name only. Maintaining such a relationship between husband and wife is painful for both sides, and it is even worse for the growth of children who are studying in high school. In addition, the defendant has not been responsible for his family for many years, and his income from running an individual hotel is very high, but he has never delivered it to his door, deliberately concealing his income and his place of residence is not fixed. This is still the case during marriage. If the divorce judgment is to pay child support by installments, it is a dead letter and cannot be implemented at all. So I asked the defendant to pay alimony in one lump sum. To sum up, please ask the people's court to support the plaintiff's claim and safeguard the legitimate rights and interests of my daughter and me.

Civil Complaint of Arrears Article 4 The plaintiff:

Defendant:

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.

Civil Complaint of Arrears Article 5 The plaintiff:

Defendant:

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.

Civil complaint of arrears 6 Plaintiff:

Defendant:

Litigation request:

1, and sentenced the defendant to repay the arrears of 900,000 yuan.

The defendant was sentenced to bear all the litigation costs of this case.

Facts and reasons:

On xx, xx, the original debtor xx transferred the debt of 900,000 yuan owed to the plaintiff to the defendant, and the defendant agreed to bear it, and issued a repayment commitment letter to the plaintiff on the spot, promising to repay the debt on xx, xx. If it cannot be repaid, it shall be repaid directly at the price of all its houses. The plaintiff also agreed. However, the defendant neither repaid the debt within the agreed time limit nor transferred his house to the plaintiff's name as agreed, which seriously damaged the plaintiff's legitimate rights and interests.

To sum up, in order to safeguard their legitimate rights and interests, the plaintiff filed a lawsuit in your hospital in accordance with the provisions of the General Principles of Civil Law, Contract Law and Civil Procedure Law of our country, requesting a judgment according to law.

Civil Complaint of Arrears Article 7 The plaintiff:

Defendant:

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.

Civil Complaint of Arrears Article 8 The plaintiff:

Defendant:

Litigation request:

1, and ordered the defendant to pay the plaintiff 30,640 yuan according to law;

2. Order the defendant to bear the litigation costs according to law.

Facts and reasons:

20xx 10, the plaintiff sold sandstone to the defendant. After receiving the goods from the plaintiff, the defendant owed the plaintiff money for a long time, owed the plaintiff RMB 30,460, and issued an iou. The plaintiff repeatedly urged money, but the defendant shirked it unreasonably and had no sincerity to pay.

Now the plaintiff's legitimate rights and interests have been infringed. In order to safeguard the legitimate rights and interests of citizens, I hope the people's court will make a judgment according to law and judge it as a petition.

Civil Complaint of Arrears Article 9 The plaintiff:

Defendant:

Litigation request:

1. Request the people's court to judge the defendant to repay the plaintiff's principal and interest of 78,470 yuan according to law;

2. Adjudicate the defendant to pay the plaintiff a penalty of RMB xxx;

3, the plaintiff to realize the creditor's rights and entrust a lawyer's fee of 3000 shall be borne by the defendant;

4. Other relevant expenses incurred in this case shall be borne by the defendant.

Facts and reasons:

On May 4, 2008, the defendant xxx borrowed 100000 yuan from the plaintiff XXX. Both parties agreed that the defendant would pay off the loan to the plaintiff one hour before the bank closed on the afternoon of June 14, xx, and the transportation fee after the bank closed was 100 yuan. The above-mentioned loan is an interest-bearing loan, and the interest will be calculated at the rate of 3% every month from the date when the defendant receives the above-mentioned money.

If the defendant fails to return the loan to the plaintiff in time after the expiration of the loan period agreed by both parties, it shall be deemed that the defendant has breached the contract, and the defendant shall compensate the plaintiff for each day overdue. At the same time, the defendant handed over the legal assets under his name to the plaintiff for debt settlement, and unconditionally cooperated with the plaintiff to handle the auction, change, bank mortgage and other related procedures. At the same time, all expenses incurred by the plaintiff to realize the creditor's rights, including court fees, execution fees, attorney fees and other related expenses, shall be borne by the defendant.

The defendant returned 60,000 yuan to the plaintiff by bank transfer on June 10+02, xx.

According to "Several Opinions of the Supreme People's Court on People's Courts Handling Lending Cases", the interest rate of private lending can be appropriately higher than that of banks, but the maximum interest rate shall not exceed 4 times that of bank loans in the same period.

Accordingly, the plaintiff demanded that the two defendants return the principal of 60,000 yuan, plus interest of 18470 yuan, liquidated damages of 6 1000 yuan and lawyer's fees of 3,000 yuan. All items are 65438 yuan +042670 yuan.

According to the loan agreement and the provisions of Article 25 of the Civil Procedure Law of People's Republic of China (PRC), our bank filed a lawsuit in your hospital, requesting to safeguard the plaintiff's rights according to law.

Civil Complaint of Arrears 10 Plaintiff:

Defendant:

Litigation request:

1. ordered the defendant to pay 80,000 yuan for personal injury compensation to the plaintiff;

2. Order the defendant to pay the plaintiff compensation for mental damage 1 10,000 yuan;

3. Compensation for the plaintiff's moped loss of 6000 yuan;

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

Facts and reasons:

20xx On the afternoon of April 1 day 1 hour, the plaintiff was hit by a minibus (brand xxxxX) driven by the defendant Yan X while riding a moped at the intersection of xx Road and XX Road in XX City, causing the plaintiff's head to fall to the ground directly and many injuries to his body, and the plaintiff's moped was seriously damaged. After the accident, the plaintiff was taken to hospital for treatment. After outpatient diagnosis, the plaintiff suffered from X-base fracture of the head, subcutaneous hematoma of the left temporal apex, tenderness and deafness. It was later confirmed by the traffic patrol detachment of xx Public Security Bureau that the defendant was fully responsible for the above accident and the plaintiff was not responsible (see evidence 1). On June 20xx 18, the plaintiff was confirmed by the disability appraisal of xx Appraisal Center that "the X-base fracture caused by a road traffic accident caused headache, dizziness and dysfunction in the left ear, which was a grade 10 disability" (see Evidence 2). On July 30, 20xx, the two sides failed to reach an agreement, and the traffic police issued a mediation conclusion on road traffic accident damage compensation.

The plaintiff suffered a brain injury, and the hospital issued a notice of admission on May 9, 20xx, requiring the plaintiff to be hospitalized for surgery. However, because the cost of hospitalization was as high as 1000 yuan, and the defendant refused any compensation at that time, the plaintiff had to give up the opportunity of hospitalization (see evidence 4). Now it has caused the plaintiff to have sequelae, such as headache, dizziness and tinnitus. And have to be dismissed by the original unit, so far can not go to work normally.

In addition, due to the accident, the plaintiff's moped was seriously damaged and is still in the defendant's place. Moreover, due to the defendant's failure to fulfill the obligation of repair and return, the moped has been scrapped, resulting in the plaintiff's economic loss of 6000 yuan.

To sum up, the plaintiff thinks that the defendant's behavior obviously constitutes infringement on the plaintiff, and directly causes personal injury and economic loss to the plaintiff. Accordingly, the plaintiff filed a lawsuit in accordance with the law to safeguard his legitimate rights and interests, and urged the court to support the plaintiff's claim.

Civil complaint of arrears 1 1 Plaintiff:

Defendant:

Requested items:

1. The defendant was ordered to repay RMB arrears and corresponding interest according to law.

The defendant should bear the legal costs of this case.

Facts and reasons:

The plaintiff and the defendant used to do business. By xx month of XX year, the defendant owed RMB 10000 yuan to the plaintiff, and the defendant 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 his debts, and the defendant returned RMB in cash one after another, only paying RMB with the goods, but still owed RMB.

Therefore, in order to safeguard the plaintiff's legitimate rights and interests, according to the provisions of Article 108 of the Civil Procedure Law, we hereby file a lawsuit and request to support the plaintiff's claim according to law.

Civil Complaint of Arrears 12 Plaintiff:

Defendant:

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 2, the younger brother of Defendant 1, signed an agreement with Plaintiff and Defendant 1 on xx, 20xx, stipulating that Defendant 2 was the guarantor of Defendant 1' s loan.

To sum up, the plaintiff has no choice but to protect 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.

Article 13 of civil complaint for arrears plaintiff:

Defendant:

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 xx, XX, XX, the original debtor xxx 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 refused to repay the debt for various reasons and excuses, which seriously damaged the legitimate rights and interests of the plaintiff.

Article 14 of the civil complaint for arrears plaintiff:

Defendant:

Litigation request:

1, and ordered the defendant to pay the remaining contract price of xxxxxxx yuan;

2. Order the defendant to pay a fine of RMB xxxx;

The defendant was sentenced to bear the legal costs of this case.

Facts and reasons:

On April 7, 20xx, the plaintiff xx xxxx Air Conditioning Equipment Co., Ltd. signed a contract with the defendant xx xxxx Building Decoration Co., Ltd., and the plaintiff contracted the XXXXXX project contracted by the defendant. The defendant shall pay the plaintiff the total price of xxxxxxxx yuan according to the agreed schedule, which shall be paid within one year, that is, before April 7, 20xx. Plaintiff completed the installation on July 4th, 20xx, and conducted debugging with defendant * * * on July 1 1. Normal operation and acceptance, fully fulfilling the contractual obligations. At present, as of June 27, 20xx, the defendant still delayed the payment of xxxxxxx, and the plaintiff's repeated reminders were of no help. In addition, it is stipulated in the contract that if the defendant fails to make payment within the time stipulated in the contract, he shall pay the plaintiff a penalty of 1‰ of the total contract price for each day overdue, but the total penalty shall not exceed 20% of the total contract price. From April 7, 20xx to June 27, 20xx, if the defendant delays for 447 days, he shall pay a penalty of 20% of the total contract price, that is, xxxx yuan.

As stipulated in the contract, if there is a dispute between the original defendant and the defendant and negotiation fails, a lawsuit may be brought to the people's court where the plaintiff is located. There is no hope for the plaintiff to urge him to defend his rights. According to the contract and the relevant provisions of the Contract Law and the Civil Procedure Law, he brought a lawsuit to your hospital and asked the court to make a judgment according to law.