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Plaintiff for the crime of occupying public places: XXXX Property Management Office of XXXX Management Co., Ltd., XX City.

Address: Room E0 1, XXXXE Building, XXX Road, Shenzhen.

Person in charge: Wang Chuanbing

Entrusted Agent Zhu Huilin Tel: 1

Lawyer of Guangdong Junru Law Firm

Defendant 1: Wen Mou

Id number: 51021xxxxxxxxxxxx

Address: Floor 2, XXXX Building, Luohu District, Shenzhen, China.

Defendant 2: Zhongdian Kindergarten in X District, Shenzhen.

Address: Floor 2, XXXX Building, Luohu District, Shenzhen.

Legal Representative: Dong XX

Litigation request:

1. The defendant registered in the management office;

2. Defendant II provided the basis for its legal use of XXXX Complex Building in Li Antang, Luohu District, Shenzhen;

3. Dismantle relevant facilities, restore the original state, and stop encroaching on the public parts of the community.

Facts and reasons:

1. The defendant registered in the management office;

Inquired by the management office, the property owner of XXXX Complex Building was transformed into the personal property right of the defendant Wen on June 65438+1October 2 1. However, since the date of change, more than two months have passed, and none of the defendants went to the management office for filing and registration. As the property service unit of the community, the management office has the obligation to register all the owners and lessors of the community with comprehensive information.

2. Defendant II provided the basis for its legal use of XXXX Complex Building in Li Antang, Luohu District, Shenzhen;

The owner was changed to defendant Wen Yi, and defendant II, as the actual property user of XXXX Complex, should provide the basis for its legal use to the residential property management office. However, since the change of property right on June +2654381October +0, Defendant II failed to provide the management office with the basis for legal use.

3. Dismantle relevant facilities, restore the original state, and stop encroaching on the public parts of the community.

(1) Defendant II transformed the public part of the back door of XXXX Complex into a lounge without authorization.

The platform and stairs at the back door of XXXX complex belong to the public area of the community and are usually used by pedestrians. However, defendant 2 changed it into a lounge and locked it without authorization, which caused inconvenience to the owners of the community and caused great dissatisfaction.

(2) Defendant II closed and locked the outer patio and piled sundries in it.

Defendant 2 closed and locked the patio of the external wall of the residential building without authorization, and piled up sundries in it. The patio of the external wall of residential building belongs to the public part of residential area and belongs to all owners of residential area. There are valves for domestic water and fire water in the community, and Defendant 2 closed and locked them, and piled up sundries for personal use, which brought great inconvenience to the possible story rescue. This behavior of the defendant caused great dissatisfaction among the owners of the community.

(3) Defendant 2 installed an air-conditioning host in the garage of the residential area without authorization.

Defendant 2 installed four air-conditioning hosts in the garage of the residential area without authorization, which occupied the public space in the garage of the residential area and discharged a lot of hot air, which caused the owners of the residential area to be extremely dissatisfied and complained to the management office for removal.

(4) Destroy the wall of residential monitoring room.

Defendant 2 punched the wall of the community public monitoring room without permission.

To sum up, according to Article 12 of the Measures for the Administration of Residential Interior Decoration, decorators and decoration enterprises shall not occupy public space or damage public parts and facilities when engaging in decoration activities. Accordingly, the plaintiff asked the defendant to dismantle the above facilities, restore them to their original state, and stop occupying the public parts of the community.

I am here to convey

XX District People's Court of XX City

Plaintiff: XX XXXX Management Co., Ltd.

XXXX Property Management Office

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