Civil litigation of disputes over sales contracts

Complaint for disputes over sales contracts Part I Plaintiff: XX, male, Han nationality, born on, address: Garden Building, province and city, ID number:.

Defendant: 1, female, Han nationality, born on, address: Garden Building in provinces and cities, ID number:. Tel:.

Defendant: 2, male, Han nationality, born on 19871October 8, with the address of Garden Building in the province and city, and the ID number:. Tel:.

Litigation request:

1. The defendant was ordered to pay the plaintiff a penalty of RMB 4 1 000, and the purpose of the house sales (intermediary) contract could not be achieved due to the defendant's reasons, resulting in a loss of RMB 340,000 from the house premium and a return of RMB 50,000 from the house purchase price, totaling RMB 800,000.

Second, the defendant was ordered to bear all the litigation costs in this case.

Facts and reasons

The plaintiff and the defendant 1 signed the House Purchase and Sales (Intermediary) Contract on September 5, 2065438 (hereinafter referred to as? Sales contract? ), with the intermediary service provided by XXXXXX Brokerage Co., Ltd., the plaintiff jointly purchased the property jointly owned by Defendant 2 and Defendant 1 * * located in Room XX, Building XX, XXXXXX District (the property ownership certificate shows that Defendant 2 and Defendant 1 are husband and wife). The contract clearly stipulates the transaction deposit, payment method, delivery and transfer time, property right status, tax and fee commitment, liability for breach of contract, etc. Defendant 2 was away on business, so Defendant 1 contacted Defendant 2 as plaintiff and intermediary, and Defendant 2 agreed to sell the property with Defendant 1.

20 1 5165438+1On October 4th, the defendant1requested to terminate the contract on the grounds that the house price fluctuated greatly during this period and the husband and wife did not buy a new house with a suitable price. The plaintiff refused and asked the defendant to continue to perform the contract.

It is also known that after the signing of the sales contract, the house price in this lot has risen sharply, and now the house price in this transaction has increased to about 2.8 million, which is 750,000 yuan higher than that of the original and defendant. The liquidated damages agreed in the sales contract can no longer make up for the plaintiff's actual losses, so the defendant is required to pay the house price separately.

The plaintiff believes that the sales contract signed by the original and the defendant is legal and valid, and both parties should perform it as agreed. If the defendant cannot continue to perform the contract due to breach of contract, the defendant shall bear the liability for breach of contract as agreed in the contract. However, the liquidated damages agreed in the contract are not enough to make up for the plaintiff's actual losses. According to the provisions of Article 1 14 of the Contract Law of People's Republic of China (PRC) and Article 6, paragraph 5 of the Sales Contract, the defendant is required to pay a penalty of RMB 4 10000, and bear the loss of the premium part of the transaction house.

In order to safeguard the legitimate rights and interests of the plaintiff, we now appeal to your hospital in accordance with the law and request a judgment according to law.

I am here to convey

XXXXXX People's Court

Shaping people:

Date:

Complaint for disputes over sales contracts Part II Plaintiff: Li XX, male, Han nationality, born on XX, XX, living in XXXXX, telephone number: XXXXX.

Defendant: Zhang XX, male, Han nationality, born on XX, XX, living in XXXXX, telephone number: XXXXX.

Litigation request:

1. Request the court to order the defendant to handle the house ownership certificate for the plaintiff immediately;

2. Request the court to order the defendant to pay the liquidated damages for overdue handling of the house ownership certificate;

3. Request the court to order the defendant to bear the litigation costs of this case.

Facts and reasons:

The original and the defendant signed the Commodity House Purchase and Sales Contract on XX, XX, XX, XX, and the contract stipulated that the defendant should handle the house ownership certificate for the plaintiff before XX, XX. However, until XX, XX, the defendant still failed to handle the house ownership certificate for the plaintiff. After repeated reminders by the plaintiff, the defendant still shirked responsibility for various reasons, and the defendant's behavior seriously damaged the plaintiff's interests.

Therefore, the plaintiff has brought a lawsuit to the people's court in order to safeguard his legitimate interests. I hope your court will support the plaintiff's claim.

I am here to convey

XX people's court

Shaping people:

date month year

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Fan: Civil complaint (sales contract dispute)

Civil appeal

Plaintiff: Address: Organization Code: (hereinafter referred to as)

Defendant: Address: Organization Code:

(hereinafter referred to as?

? )

Claim 1. In, the defendant paid RMB * * owed to the plaintiff every month, and the payment date determined by the effective judgment was calculated according to the bank loan interest rate of RMB for the same period. )

Pay interest (until the date of prosecution, the interest is 2. The litigation costs of the case shall be borne by the defendant. Facts and reasons The plaintiff company has business dealings with the defendant company, and the agreed payment method is 30th of each month. The defendant and the plaintiff still paid RMB in July, August and September of 20xx, but at present, the company has not paid RMB for purchasing materials. In order to protect their legitimate rights and interests, the plaintiff sued and demanded fair treatment according to law. The specific application is described above. Bring a suit in a people's court

The company has decided to bring a lawsuit to your hospital.

Prosecutor (official seal): Date: