Defendant Lianshui PICC Property Insurance Company.

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Huai 'an, Jiangsu Province, a beautiful historical and cultural city, together with Yangzhou, is the birthplace of Huaiyang cuisine. Recently, there is a story about a civilian who sued the State Council for having a hard time. His name is Xu Congdong, born in 1968, Huai 'an. However, because of a government land acquisition fraud and unfair compensation incident on 20 10, he became familiar with the law and embarked on the road of petitioning for rights protection countless times. During this period, he petitioned and appealed many times. In the face of protecting officials and intimidation, he did not flinch at all. He has experienced dozens of lawsuits, big and small, and has never been afraid. He is speaking with legal facts. So, what's going on with Xu Congdong?

According to Xu Congdong, in April of 20 10, the Huai 'an government of Jiangsu Province expropriated land, and the resettlement houses of Xu Congdong 1 mu of land were expropriated, according to him; The whole village * * * expropriated 69.04 mu, but at that time, the government concealed that it only registered and reported 15.04 mu of land, resorted to fraud and unfair compensation, and repeatedly sought the government's theory, but failed. ?

20 12 September, petitioning? When Xu Congdong petitioned, he was illegally detained in a private black prison and forced to write a transcript by electricity. (1) Xu Congdong raped a young girl. (2) The short message in Xu Congdong's mobile phone number 1340 1832998 was copied by them, creating an illusion. The illegal confession was written by a leader of Lianshui Economic and Technological Development Zone, forcing Xu Congdong to make a record. (3) The written materials for forcing Xu Congdong to obtain bail pending trial are guaranteed by Pu Liangfeng, a village party secretary. The following is Xu Congdong's administrative lawsuit. ?

Administrative litigation?

The plaintiff Xu Congdong, male, Han nationality, lives at No.27, Goubei Group, Ma Tao Neighborhood Committee, Lianshui Economic Development Zone, Jiangsu Province. Tel: 1340 1832998. ?

Defendant: Jiangsu Provincial People's Government?

Legal Representative: Li, and Position: Governor. ?

Address: No.68, Beijing West Road, Nanjing, Jiangsu. ?

Claim:?

Revoke the Decision of Jiangsu Provincial People's Government on Not Accepting the Application for Administrative Reconsideration [20 15] Su Xing Fu Bu Zi No.46, perform legal duties according to law, and return it to Su Zheng No.6216 [20/KLOC-0]. Make a decision to cancel. ?

The news media are required to broadcast the trial live.

Facts and reasons:

The plaintiff applied to the provincial people's government for cancellation on September 28, 20 12. Notice on Approving the Fourth Batch (10) of Construction Land for the Construction Project of Lianshui beicheng (documentNo. [20 10] 62 16 of Su Zheng), dated 20 12 19. Notice of Acceptance of Administrative Reconsideration of Jiangsu Provincial People's Government, [20 13] Su Xingfu No.8, (the original was burned by family members), 20 13 65438+24 10, Jiangsu Provincial Legislative Affairs Office: Director Yang and Li Yu; Provincial Department of Land and Resources: Gao Yang: I came to Lianshui to see the land acquisition site and held a hearing. At the hearing, Li Yu handed over the administrative reconsideration instruction from the Jiangsu Provincial Department of Land and Resources. , Tu Zi [20 10] No.890 and other relevant materials, and took out the plaintiff's "Application for Cancellation of Illegal Land Use in Xinlianzhong, Wugaisan Resettlement Community" and the photo of "General Land Use Plan of Ma Zhu Town, Lianshui County (partial)" on the spot, pointing out that the document was altered and forged, 20 1 1 and-

At the hearing, Director Li Yu asked me to give a reply before February 26th, 20 13 according to the statutory time limit. Because of the Spring Festival holiday, Director Li Yu asked the plaintiff, "Because I can't give a written reply within the statutory time limit, can I postpone the Spring Festival holiday?" The plaintiff replied, "Yes, just give an extension notice." ?

201365438+1October 3 1 Jiangsu provincial people's government decided to postpone the notice [20 13] su xingfu No.8, you are no longer in the "provincial government's approval of the fourth batch of new districts (10) 20/kloc-0" According to the provisions of Article 31 of the Administrative Reconsideration Law of People's Republic of China (PRC), the administrative reconsideration decision was postponed to 201March 318th.

According to the plaintiff Xu Congdong, on March 2, 20 13, he went to work in the first management department of Nanjing Jiangdong Middle Road Reconstruction Project Headquarters of China Railway Fourth Bureau Co., Ltd. and Bing Lin of Huai 'an Construction Labor Service Co., Ltd., accompanied by the secretary of discipline inspection of Lianshui Economic Development Zone, the instructor of the police station, the senior stationmaster of the family planning office (female), Pu Liangfeng, Jin and others at 1 p.m., Many people took the plaintiff away by illegal coercive violence and took him back to Lianshui County, where he was detained on the second floor of Taoliyuan Hotel in the south of the former Lianshui No.1 Middle School (I don't know who told the plaintiff to take off his work clothes and hold his head when getting off the bus, so that he could not see the place where he was detained). When he got off the bus, he hugged the plaintiff's waist, someone held his head with clothes, someone grabbed his arm, dragged too many chefs back, pushed the plaintiff to the second floor and pressed his mobile phone on the plaintiff. All the money and things were searched, the plaintiff was forced to take off his shoes and his belt was taken away by force. The object of corporal punishment is to hit the plaintiff with a stick when his toes, knees, chest and head are not facing the wall, which violates the law and is beyond his power.

Every day, there are four fixed personnel guarding the plaintiff, including the former village head and current accountant He Chuanhai, the team leader Jin and the police station Feng and Liu. Village secretary Pu Liangfeng runs up and down maliciously every day. He threatened the plaintiff and induced him to quit Su Xingfu. [2013] No.8, the application for administrative reconsideration was withdrawn. Jiangsu Provincial People's Government: I applied to the provincial people's government on September 28th, 20 12, requesting the cancellation of Su Zhengdi [20 10] Document No.6216. Now the application problem has been solved through coordination, and I voluntarily withdrew the application No.2065438 for administrative reconsideration.

Signature of plaintiff. If you don't agree to sign, the plaintiff will not be spared. Pu Liangfeng said, "If you don't sign it, I won't spare you this time. Do you remember being detained for the first time from September 20 12 to September 26/20 12? This time, you will be punished more severely. You have to agree to sign it to save your life?

They maliciously used illegal broken hands to collect evidence and cover up illegal facts. On March 5, the plaintiff was beaten by Pu Liangfeng, the village secretary, and operated in a black box under the condition of restricting personal freedom. The telephone was connected well with Director Li Yu of the Provincial Legislative Affairs Office. When answering the phone, many people raised their fists at the plaintiff's head Secretary Pu Liangfeng took the plaintiff's mobile phone to answer Director Li Yu's question. Director Li Yu told the plaintiff that the plaintiff couldn't get through the phone many times (20 10: 52 on March 4, 2003 to 4 16: 48 on March 2003). You can't call the same number at 08: 35 on the second and fifth day of the same month.

Director Li told the plaintiff on the phone that the Administrative Reconsideration Law has only one chance, and there is no second chance. Please consider it carefully. I raised my fist at the plaintiff's head in many people, and the plaintiff only answered Director Li's question. In desperation, the plaintiff had to answer. Director Li Yu, please think about it and give an answer tomorrow.

On the evening of March 5th, a man named called himself Lianshui Economic Development Zone, called Big Wolf Dog a black-and-white expert, and Kong threatened to withdraw document Su [20 13]8. If he doesn't withdraw, he will organize his brothers to follow the plaintiff every day, and he can use his car to chase the plaintiff when the traffic accident comes. The plaintiff only agreed to his request. For the sake of the plaintiff's life safety, after Xu Liang left, He Chuanhai, a member of the villagers' meeting, wrote a reply to Director Li Yu's question the next day. "Director Li, I'm Xu Congdong from Lianshui, about my application for cancellation of administrative reconsideration. It has been solved now. Thanks to the concern of the leaders, I have worked hard in Lianshui. Tel: 02583396437.3.6 Under the secret operation of Secretary Pu Liangfeng, Jin, He Chuanhai, Pu Liangfeng and the stationmaster of the Family Planning Office were present. Before answering the phone, they forced the plaintiff to answer according to He Chuanhai's written answer, otherwise the plaintiff would die. They arranged for the secretary Pu Liangfeng to answer the phone with the plaintiff's mobile phone, so the escort raised his fist to the plaintiff's head. For the sake of life safety, he had to answer questions according to their written answers. After talking with Li Yu, director of the Provincial Legislative Affairs Office, Zhang Hongbing, secretary of the Commission for Discipline Inspection, called Pu Liang Shu and asked him to agree to withdraw. " Zhang Hongbing said on the phone, it is good to withdraw. "Please ask the leaders of state organs to sign the revocation of document Su Xingfu [20 13] 8 by means of illegal kidnapping, illegal detention, intimidation and deception. According to Article 52 of People's Republic of China (PRC) Contract Law, the signing of this contract is invalid. On March 8th, the original defendant was taken to the police station for temporary id card, and Pu Liangfeng, the village secretary, bought a suit of coat and underwear for the plaintiff according to He Chuanhai's arrangement. Pu Liangfeng asked the plaintiff to pay a receipt of 20,000 yuan, which was later collected by his wife Wang Shizhen. On March 6th, 5438+4, the plaintiff was taken to Xi 'an, another province in the name of tourism.

I have no money, my mobile phone has been searched, and four people are inseparable, controlling personal freedom. On March 17, I returned to Lianshui from Xi 'an.

What is the charge of not detaining any written materials at noon on June 5438+08?

20 13, 12, Jiangsu provincial people's government made the decision to terminate the administrative reconsideration of [20 13] Su Xingfu No.8?

20 14, 1044978095 13, application for information disclosure. 20 13 During his detention from March 2 to June 8, he was illegally detained, threatened, seduced and cut off his hand.

Your company's reply of 20 15 65438+ 10/2 does not apply to the provisions of the Regulations on the Openness of Government Information.

20 15, 1, 3 1, the plaintiff applied to the provincial legislative affairs office by domestic registered letter XA77085993032. On February 1 1, the plaintiff went to the case storage office of the provincial government to receive the defense of each department.

After reading it, I found that many arguments were forged, deceptive and deceptive. On March 3, 20 13, I returned to apply for administrative reconsideration. I don't know who will withdraw the application for administrative reconsideration. The handwriting is troublesome for Director Li Yu to receive, and it is recorded in pencil: "On March 5, 20/kloc-0, the applicant called to confirm the withdrawal of the application, but his words hesitated." ?

On March 6, 20 13, the management Committee of Lianshui Economic Development Zone forged legal documents to deceive the case-handling personnel of the Provincial Legislative Affairs Office. Party A: Jiangsu Lianshui Economic Development Zone Management Committee. Party B: Xu Congdong. After friendly negotiation between Party A and Party B, Party A carefully examined the issues raised by Party B, and on the basis of fully considering Party B's interests, taking into account various factors such as Party B's very difficult family life, with the consent of both parties, Party A gave Party B a one-time economic compensation of 20,000 yuan.

At the same time, Party B voluntarily withdrew the administrative reconsideration of the provincial government land use approval [20 10] No.6216.

Party A: Qiao Yunde, Administrative Committee of Jiangsu Lianshui Economic Development Zone. Party B: Xu Congdong. The plaintiff was illegally detained in Taoliyuan Hotel in the south of Lianshui County on March 6th. I didn't see Qiao Yunde in the hotel, and I didn't sign 2065 438+03. 3. 6. The local government is stealing flowers and hurting the plaintiff.

20 13 65438+2006 10/4/0. There are many inconsistencies in the manual of Huai 'an Municipal People's Government as follows.

1. Notice (Su Zhengdi [20 10] No.6216) on approving the fourth batch (10) of construction land in Lianshui County.

Reply on the implementation plan of 20 10 linking urban and rural areas in Lianshui county. Summary table of land ownership of construction requisition (occupation) land, barcode 320826 110123, project name: Jianxin District, Lianshui County, 20 10/No.1batch (No. Among them, cultivated land 132. 1467 hectares, land to be requisitioned 1.0226 hectares (15.40 mu), of which cultivated land is 0.9503 hectares. The actual land use is 69.04 mu, and 53.64 mu is concealed.

The newly-built area 1 plot (10 plot) of the urban and rural construction land increase and decrease project in Lianshui County was changed to 20 10 plot 4, and the classified area of construction land was summarized, with barcode: 320826 1 1065438+. Ma Tao Juhui, Economic Development Zone, Lianshui County, Jiangsu Province, has a total area of 10226 square meters of agricultural land, 9,503 square meters of cultivated land, 9,503 square meters of irrigated land and 763 square meters of other agricultural land, totaling 10226 square meters. The actual land is 46,028.9680 square meters of agricultural land and 37,890 square meters of irrigated paddy fields. ?

Bar code of the application description of construction land project: 320826111123. Application unit: Lianshui County People's Government. Name of construction land project: No.4 batch (10) of Jianxin District 20 10 of urban and rural construction land hanging structure project in Lianshui County. The plot of construction land 20 10 hanging structure -4- 10 is 2.4643 hectares. Jianxin District 1 Summary of Land Classification Area of Batch Construction Land 20 1 1 (Hook 10) is linked to the increase or decrease of urban and rural construction land in Lianshui County: barcode: 32082610123. According to the form of Ma Tao Neighborhood Committee of Jiangsu Lianshui Economic Development Zone, the difference between the same barcode is 1.0226 hectares (15.04 mu), and the difference between them is 1.44 17 hectares. The actual land acquisition is 4.6027 hectares (69.04 mu).

Two. Organization and implementation of the Notice on Approving the Fourth Batch (10) of Construction Land in Lianshui New District 20 10 (Su Zhengdi [2010] No.6126).

1. The collective land of Ma Tao residents' committee 1.0266 hectares is used for the construction of new resettlement areas linked to the increase or decrease of construction land. The owner of this collective land, Ma Tao Cungou North Group, is agricultural land (including 0.9503 hectares of cultivated land and 0.0763 hectares of other agricultural land). The actual land area is 4.6027 hectares. It is used for the construction of new resettlement areas linked to the increase or decrease of urban and rural construction. The owner of this collective land belongs to the North Group of Cungou, Ma Tao. He cheated, deceiving his superiors and deceiving his subordinates, and underreported 53.438+0 mu of land, involving 9 households contracted by this group and actually occupying 42 households' land. It is a serious violation of Article 42 of the Property Law of People's Republic of China (PRC) to pay monetary compensation to farmers who contract land according to the compensation standard for land acquisition of Huai 'an Municipal People's Government. Ministry of Land and Resources of the People's Republic of China, Ministry of Human Resources and Social Security of the People's Republic of China and Ministry of Supervision of the People's Republic of ChinaNo. 15. Item (2) of Article 13, if the social security fee has been implemented at the end of the current period, it shall not be approved.

According to: 2012 65438+administrative reconsideration instruction of Jiangsu Provincial Department of Land and Resources on February 30th.

Two. List of legal basis for examination of construction land.

1. Violation of the Land Law of People's Republic of China (PRC); ?

2. Violation of the Regulations of the People's Republic of China on the Implementation of the Land Management Law:

3. Violation of the State Council's Decision on Deepening Reform and Strict Land Management (Guo Fa [2004] No.28); ?

4. Violation of the Notice of the State Council on Strengthening Land Regulation (Guo Fa [2006] No.31); ?

5. Violation of the Regulations of Jiangsu Province on Land Management;

To sum up, the provincial government made the Notice on Agreeing to Link the Increase and Decrease of Urban and Rural Construction Land in Lianshui County to build the fourth batch (10) of construction land 20 10. The illegal facts are clear, the illegal facts are well founded, and the procedures are all illegal.

According to the basic principle of illegal and invalid administrative law, the document "Su Zhengdi [20 10] No.6216" should be revoked, the applicant's land should be returned to the applicant, and all losses of the applicant should be compensated.

According to the provisions of the Administrative Procedure Law of the People's Republic of China, we filed an administrative lawsuit with your hospital and requested your support.

According to Xu Congdong, he has repeatedly prosecuted these illegal departments according to law and made many judgments, but the results of the judgments made him very dissatisfied. Obviously, these departments knew the law and violated the law, illegally and forcibly prevented him from petitioning without official documents, and kidnapped him for intimidation and fraud. Why is it that under such irrefutable evidence, officials cover up for each other, but the court does not treat their crimes and cannot give themselves justice? Where are the laws in China? What else do you say about governing the country according to law? Is this the rule of law? ?

Finally, Xu Congdong said: Although officials protect each other and the lawsuit is lost in nine cases out of ten, he will continue to fight. Since China is a country that runs the country according to law, he would like to see how these officials enforce the law. He will lift the veil of darkness layer by layer and dig out the laws of China! We can't let the national laws be destroyed by some corrupt elements in the absolute monarch. ?

Due to the long-term violation of law and discipline by local cadres, the injured individual industrial and commercial households can't operate, and have been closed for many years, resulting in family breakdown, family separation, nowhere to live, and heavy losses! ?

When fighting this lawsuit, he always had four concepts in his mind. First, the court must admit that the government has violated the rules; Second, publicly apologize to yourself; Third, give those people reasonable compensation as soon as possible; Fourth, compensate them for their personal losses. ?

No matter how difficult the lawsuit is, he will continue to fight for dignity. He expects the country to give himself and the victims justice!