1. How to write the defense of divorce property division mode?

prologue

1, title. Write "defense of divorce property division" in the middle.

2. The basic information of the person under investigation. Indicate the name, gender, date of birth, nationality, occupation, work unit, position and address of the respondent. If the respondent is a person without capacity for conduct, the name, gender, date of birth, nationality, occupation, work unit, position, address and relationship with the respondent shall be stated after the project; If the respondent is a legal person or other organization, it shall indicate its name and address, and the name and position of its legal representative (or principal responsible person). If the respondent entrusts a lawyer to represent the lawsuit, the name of the agent and the name of the law firm where the agent is located shall be stated after this item.

3. Reasons for reply.

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1. reasons for defense: the plaintiff's or appellant's claim and the facts and reasons on which it is based shall be refuted and defended. The appellee's defense mainly aims at the appellant's facts, reasons, evidence and claims from the substantive aspect, and denies all or part of the facts and evidence on which it is based, thus denying its reasons and claims. The defendant's defense in the first instance can also be defended from the procedural aspect, for example, the plaintiff is not a legitimate plaintiff, or the case prosecuted by the plaintiff does not fall under the jurisdiction of the Court of Appeal, or the plaintiff's prosecution does not meet the statutory conditions for prosecution, indicating that the plaintiff has no right to prosecute or prosecute illegally, thus denying the case. Whether the defendant in the first instance or the appellee in the second instance put forward the defense reasons, they should be realistic and have evidence.

2. Request for defense: Request for defense refers to the request made by the respondent to the people's court to protect the legitimate rights and interests of the respondent on the basis of clear defense reasons and in accordance with relevant laws and regulations. The defense requests in the civil defense of first instance mainly include:

(a) request the people's court to dismiss the prosecution and refuse to accept it;

(2) Request the people's court to reject all or part of the plaintiff's request;

(3) Put forward new ideas and requirements, such as adding a third person;

(4) counterclaim. If there are more than two claims in the civil defense, the claims shall be explained item by item. The defense request of an appeal shall support the original judgment or ruling and refute the appellant's request.

3. Evidence: The name, number, source or clue of evidence shall be stated in the defense. If there is a witness, the name and address of the witness shall be stated.

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1, name of people's court.

2. Signature of the respondent. If the respondent is a legal person or other organization, it shall indicate the full name and affix the official seal of the unit.

3. It's time to reply.

4. The attachment shall mainly indicate the number of copies of the defense and relevant evidence.

Second, how to distribute the property at the time of divorce?

At the time of divorce, the property of husband and wife shall be handled by mutual agreement; If the agreement fails, the people's court shall make a judgment based on the specific circumstances of the property and the principle of taking care of the rights and interests of the children and the woman.

1, salary, bonus. Wages and bonuses are paid by both husband and wife in their daily work, whether it is mental work or manual work. It includes not only wages and bonuses, but also various forms of remuneration income such as red envelopes, gifts and allowances, which belong to the common property of husband and wife.

2. Income from production and operation.

3. Intellectual property income.

4. Inheritance or gift of property.

5. Other property that should be owned by * * *.

Income obtained by one party through personal property investment; Housing subsidies and housing accumulation funds actually obtained or should be obtained by both men and women; The pension insurance and bankruptcy resettlement compensation actually obtained or should be obtained by both men and women belong to both husband and wife.

The defense of property division should be written by a lawyer. When handling divorce procedures, you can divide the property through consultation, and both parties need to reach an agreement and sign a divorce property agreement. If negotiation fails, you can go to court, and the court will decide to divorce, divide the property, follow the principle of equality between men and women, and take care of the interests of children.