pleadings are the documents that defendants (persons), counterclaims, appellees and respondents (defendants) answer and refute the contents of complaints, counterclaims, appeals and retrial applications (petitions) within the statutory time limit, and are one of the most frequently used languages in pleadings. The following is YJBYS's civil defense template I brought to you, hoping to help you!

Respondent:

Name: _ _ _ _ _ _ Address: _ _ _ _ _ _ _ Tel: _ ___

Legal representative: _ _ _ _ _ _ _ _ _ _ _ Title:. ____

Address: _ _ _ _ _ _ _ _ _ _ _ _ Tel: ___

Because of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. The defense is as follows:

_____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.

_ _ copies of other supporting documents.

Note: The reasons for defense should state the problems in the indictment, such as inconsistency with facts, insufficient evidence and lack of legal basis, and list relevant evidence and legal basis. Template of civil defense 2

Respondent (plaintiff of first instance, counterclaim defendant): Zhang Haiyan, female, born on July 16th, 19xx, Han nationality, now living in Industrial Street, Azhen Town, Ejinhoro Banner, Erdos City, Inner Mongolia, is an individual industrial and commercial household, and is the head of Yiqi Shengshi Talent Decoration Company.

the respondent decorated the case of the second trial of renovation contract dispute with the appellant (defendant of first instance, counterclaim plaintiff), and the reasons for the appellant's appeal are as follows:

1. The court of first instance found that the facts were clear and the evidence was sufficient, which should be maintained.

1. When the respondent and the Appellant signed the construction contract for the family room decoration project, the quotation issued to the Appellant was the final price of the project. At the end of the quotation, it was written that the final actual total cost of the project was 58, yuan, which was confirmed and approved by both parties, not the Budget Table.

2. Before signing the contract with the Respondent, the Appellant had looked for several decoration companies for comparison. One company offered a price of 1,25, yuan, and the lowest one offered a price of 98, yuan (the profit of tooling was about 45%), while the actual total cost of the Respondent's project was 58, yuan. There was no profit, but it was only made as a performance project and a model project.

3. In the whole construction process, every time the construction scheme is changed, it will be implemented only after the confirmation and approval of both parties. If the appellant is not sure about the approval, it is impossible to continue the construction and complete the project.

4. All materials and materials must be confirmed and approved by the appellant before the construction can be completed. The wallpaper is also 265 yuan per roll, and the original invoice is available. The stairs were also customized according to the standard, but the appellant did not give specific and detailed dimensions, and did not deliberately reduce the width of the stairs.

5. The fire-fighting acceptance failed because there was no sprinkler fire-fighting equipment installed in KTV. At the beginning,

during the construction, the respondent specifically proposed that "entertainment industry and other public places" must be equipped with sprinkler fire-fighting equipment, but the appellant refused to adopt the plan, saying that he had relatives in that line and could pass the fire-fighting acceptance without installing sprinkler fire-fighting equipment.

These are clear facts and sufficient evidence that the court of first instance found after detailed investigation and evidence collection, which should be maintained according to law.

second, the court of first instance correctly tried the case in full accordance with legal procedures.

1. When the court of first instance heard the case for the second time, the respondent was summoned by the court summons, and Zhao Jiangbo, the agent, appeared in court to participate in the lawsuit. The appellant refused to appear in court without justifiable reasons, so the court of first instance made a Civil Ruling, and the counterclaim in this case was automatically withdrawn.

2. The reason for the second court hearing was not because the respondent was not the court of first instance, but because the appellant counterclaimed in court during the first court hearing on March 15th, 2xx. In view of this situation, the court of first instance decided to adjourn the court and hold the court session on another day.

The respondent received a summons from the court of first instance on June 8, 2xx, and it was scheduled to hold a second hearing on June 13, 2xx at 14: 3 pm. On June 13, the respondent filed a counterclaim against the appellant and presented three pieces of evidence. However, the appellant refused to appear in court to participate in the proceedings without justifiable reasons, which was regarded as giving up the litigation right and the right to cross-examine the evidence.

to sum up, the court of first instance tried the case correctly in full accordance with legal procedures.

third, the court of first instance applied the law correctly and the procedure was legal, so the appellant's appeal grounds could not be established.

the trial by the court of first instance is in line with the relevant provisions of the civil procedure law, and there is nothing improper. All the problems mentioned by the appellant, such as the time limit for a project, the construction cost, the material quality of materials, and the failure of fire control acceptance, have been clearly stated above, and the Civil Ruling and Civil Judgment of the court of first instance < P > all indicate that the appellant's appeal reason cannot be established. As a citizen, it is understandable that the appellant enjoys legal litigation rights, but he can't make things out of thin air, gossip and create troubles in the process of litigation under the guise of legal litigation, which has caused great harm and adverse effects to the court of first instance, the respondent and his agent. These actions of the appellant are an abuse of his litigation rights.

based on the above facts and reasons, the court of first instance found that the facts were clear, the evidence was sufficient, the applicable law was correct and the procedure was legal. The court of first instance applied Article 6, paragraph 1, and Article 263 of the Contract Law of the People's Republic of China to judge that the case was well founded, reasonable and legal. The respondent believes that the appellant's appeal request cannot be established, and implores the people's court of second instance to reject his claim after the trial and uphold the original judgment according to law.

To the Intermediate People's Court of Ordos City

Respondent:

2xx July 27th civil defense template 3

Respondent: Fanchang Wanhao Real Estate Development Co., Ltd.

Address: No.84 Huancheng East Road, Fanyang Town, Wuhu City

Legal representative: Chen Jian, general manager

Respondent. The following defense opinions are put forward:

1. The respondent has announced the liquidation of the company after the establishment of the liquidation group, and the lawsuit filed by the plaintiff against the respondent for still assuming joint and several liability for guarantee should be rejected.

in the complaint, the plaintiff provided six sets of evidence, among which the liquidation report of Fanchang Wanhao Real Estate Co., Ltd. in the sixth set of evidence showed that Wanhao Real Estate set up a liquidation group on April 24, xx, and notified creditors to apply for creditor's rights. On September 29, xx, Wanhao Real Estate announced the liquidation in Wuhu Daily. On December 31, xx, Wanhao Real Estate was liquidated.

the notice of approval of cancellation of registration in the sixth group of evidence shows that the administrative department for industry and commerce of Fanchang County approved the cancellation of registration of Wanhao Real Estate in Fanchang County on April 15th, xx.

It can be seen that Wanhao Real Estate has fulfilled its obligation to inform in the liquidation process, and the fact that Wanhao Real Estate was dissolved has also been approved by the state administrative organs, so Wanhao Real Estate has died out as an independent subject of civil liability in law. The newly established Wanhao Real Estate Development Co., Ltd. is an enterprise legal person registered in the administrative department for industry and commerce according to law, and the rest of Wanhao Real Estate are different civil subjects. In the complaint, the plaintiff still demands Wanhao Real Estate Co., Ltd. to bear the debt liability that it should not bear, which is unfounded in the law.

to sum up, the plaintiff's claim lacks factual and legal basis, and requests the people's court to find out the facts and reject it according to law, so as to safeguard the legitimate rights and interests of the respondent.

This is to

People's Court of Shushan District, Hefei

Respondent: Fanchang Wanhao Real Estate Development Co., Ltd.

Template 4 of Civil Pleadings on XX, XX, XX, XX

Respondent: * *, male, Han nationality, born on XX, XX, XX, XX, XX, XX, XX, XX, XX, XX, XX, XX, XX, XX, XX, XX, XX According to the legal facts of this case, there is no emotional breakdown between husband and wife, and they do not meet the divorce conditions stipulated in the Marriage Law. The reasons are as follows:

1. The plaintiff and the respondent in this case met and established a love relationship in Shenzhen in 2xx. After more than a year of mutual understanding, they accepted each other. On the 12th day of the first lunar month in 2xx, the respondent held a wedding banquet in accordance with the local customs in Fujian, and the plaintiff was married in the door on April 5, 2xx. The long process of getting to know each other and falling in love before marriage made them establish a solid marriage foundation. The plaintiff's suggestion that "the two sides hastily combined without fully understanding each other, and the contradiction between * * * and life was constant" was not true.

2. In the complaint, the plaintiff pointed out that "the original and the defendant have different personalities, and they don't speak the same language. In addition, the defendant has a bad temper, extremely distrusts the plaintiff, and often suspects the plaintiff for no reason, which leads to the increasingly weak feelings between husband and wife, and now it has reached the point where they can't live together." The respondent disagreed with this statement. The plaintiff and the respondent will get married only when they think they are suitable for each other. They have always had a good relationship after marriage. After the birth of their son in August, 2xx, the family is even more happy and envied by others. After the husband and wife came to Changsha in 2xx, although the business was not smooth, the two sides occasionally quarreled, but they were all trivial contradictions, which were common in many families.

3. Since the plaintiff went to work in the hotel despite the respondent's objection in July this year, she began to chat with some male friends in an ambiguous tone, even staying out at night (never before), and her words flashed in the face of the respondent's inquiry. The respondent didn't suspect the plaintiff for no reason. The plaintiff is simple, and there are many temptations in today's society. The respondent criticized the plaintiff's behavior in good faith for the sake of family happiness. In order to achieve the purpose of divorce, the plaintiff deliberately exaggerated the differences and contradictions between the two sides in language. To be fair, the respondent and the plaintiff have been together for 8 years, and they have been supporting each other and their feelings have always been good. They should not talk about divorce casually.

4. After the plaintiff sued for divorce, the respondent visited her parents-in-law several times, and stayed for two or three hours each time. Because the plaintiff's place of work is close to the respondent's residence, the respondent often goes to her place of work to find her. Although the plaintiff sometimes has a bad attitude, she sometimes has a good attitude, and once said that it is still possible to remarry even after divorce.

to sum up, the respondent believes that the plaintiff's lawsuit for divorce is obviously impulsive and has a certain relationship with the poor family economic conditions in the past two years. Although the plaintiff filed for divorce, the two sides are far from reaching the level of marital relationship breakdown. No matter from the perspective of cherishing the feelings of husband and wife or caring for children, the respondent resolutely disagreed with the divorce with the plaintiff. There is a sentence in the Law of Happy Marriage by Wenger Julie: "Even the happiest marriage in this world will have the idea of divorce 2 times and the idea of strangling each other 5 times in its life." I implore the court to comprehensively consider the facts and circumstances of this case, reject the plaintiff's prosecution, and safeguard our family that should not have been disintegrated.

second, for the purpose of clarifying the facts, talk about other places in the plaintiff's complaint that are not in line with the actual situation. Mainly in the following three aspects.

1. The son has not always lived with the plaintiff in his grandmother's house since he was born. After the birth of a 2xx child and before returning to Changsha in 2xx, a family of three lived together, and the relationship between father and son has been very good so far. After returning to Changsha in 2xx, the plaintiff insisted on putting the children at grandma's house, but the respondent always disagreed. In this case, the plaintiff will go to her parents' home for 8 or 9 days every month, and the children will go back to their parents' residence when they are not in class on weekends. It is inconvenient to run back and forth, which has an impact on children's schooling and facade business.

2. The plaintiff said: "The plaintiff has never been involved in the business (painting business), so this loan should be fully repaid by the defendant himself." The respondent disagreed with this. After the respondent and his wife returned to Changsha, due to the lack of industry experience and the shortage of initial funds, I hope that the husband and wife can make concerted efforts to manage the facade well. The plaintiff and the respondent belong to the * * * joint operation, which is a "husband and wife shop", and the plaintiff is clear about the business development and lending. To say the least, the respondent engaged in paint business for the sake of family life. Even if the plaintiff didn't actually participate in the business, the loan belonged to the husband and wife's debt, not the respondent's personal debt. Of course, the respondent's business has improved at present. As the father of a husband and children, in any case, the respondent will shoulder the responsibility of the family, pay off the loan through his own efforts, and constantly enrich the family's economic foundation. I hope the plaintiff can give the respondent some time.

3. The respondent's husband and wife have debts of RMB 28,. In the course of doing business in recent years, the respondent and his wife have borrowed 28, yuan from the bank and their relatives and friends for turnover. The plaintiffs know that these loans were once admitted after the prosecution, but because of the relationship between relatives and friends, many loans were not written. Including the 1, yuan mentioned in the plaintiff's complaint, 2, yuan was not written, and the other 8, yuan was written by the plaintiff before the prosecution.

to sum up, the plaintiff's claim has no factual and legal basis, and the respondent requests the court to reject the original application according to law and make a judgment that divorce is not allowed.

To the People's Court of Furong District, Changsha City

Respondent:

Model civil defense form 5

Third person: XXX Gender: XX Age: XX Address:No. XX, Group XX, XX Village, XXXX Township, XX District, XX City

Plaintiff: XXX Gender: X Age: XX Address: Room XXXX, XX District, XX City.

Defendant: XXXXX

Address:No. XX, XX Middle Road, XX City

Plaintiff XXX made the following reply because she refused to accept XXXXX: XXXXX

Respondent now makes the following reply on the case of legal inheritance dispute originally told to Respondent:

1. The three Middle East Houses in the property complained by Plaintiff were built on the application of-and cannot be divided into the same property as * * *.

firstly, according to the Application Form for Registration and Replacement of Private Houses provided by the Housing Authority, some of them are located in-the source of the property is.