Civil indictment

     Plaintiff.Jiao Yuying, female, the Han nationality, address, contact telephone number:

Plaintiff.Zhang Yaling, female, the Han nationality, address, contact telephone number:

Defendant.Zhang Zhonghai, male, the Han nationality, the work unit, address, contact telephone number:

Defendant.Zhang Yanling, female, the Han nationality, address, contact telephone number:

Cause of action:Inheritance disputes

The claim:

 1Request according to law, decree to be located in Beijing city Haidian District Cuiwei Road property belonging to the Zhang Hongde legacy share segmentation, the property value of about18Million yuan.

 2, request any will belong to the decedent's legacy share of deposits and funeral expenses, pension17Million by the plaintiff and the defendantZhang YanlingInheritance, the defendant Zhang Zhonghai did not share or a smaller share of the estate.

 3Request in accordance with the law, order the defendant to bear the costs of litigation.

 And after the fact:

Be heir to Zhang Hongde and Jiao Yuying, the relationship between husband and wife, heirs of Zhang Hongde Jiao Yuying and the co incubation for three children, Zhang Yaling, Zhang Zhonghai, Zhang Yanling.2004Years11Month17Zhang Hongde died of an illness. Zhang Hongde was with the plaintiff Jiao Yuying the joint property of husband and wife is located in Beijing city Haidian District Cuiwei Road property set; deposit135816.62Yuan, interest505.4Yuan, a total of136322.02Element. The other in after the death of Zhang Hongde units pay give the family pension, funeral charges94012.3Element.

After the death of Zhang Hongde, Jiao Yuying after their children's consent, the husband and wife together deposits and shall issue the funeral expenses, pension after deducting the cost of remaining after the funeral17RMB deposit to their own name for temporary safekeeping. After the defendant Zhang Zhonghai in did not inform, also there are other people without the consent, to report the loss to the bank for the means, the deposits are removed, the plaintiff learned that many find the defendant Zhang sea after the matter were refused. The defendant's conduct serious violations of the legitimate rights and interests of the plaintiff.

 Here, the plaintiff according to the relevant provisions of our inheritance. According to your institute proceedings, request your hospital can support the plaintiff's claim.

                                       Like a man:

                                            Date

The word

Respected judge, judge:

Beijing city law firm shall be entrusted to the plaintiff Zhang Yaling appointed me as his inheritance and Zhang Zhonghai, Zhang Yanling heritage dispute case agent, through the investigation and the case evidence and seriously study the pretrial court investigation, combined with today, now published the following agency views:

One, the dispute of housing and bank deposits are successors of Zhang Hongde and the Jiao YuyingThe common property of the couple.

The dispute of housing is being heir Zhang Hongde and the plaintiff Jiao Yuying jointly purchase during the marriage housing, headed for by all Zhang Hongde inherited, bank deposits and Zhang Hongde and Jiao Yuying and common benefits in marriage. According to "the people's Republic of China Marriage Law" article17I think this case relates to the house of husband and wife is the heir and the common property shall be.

Two, the plaintiff Zhang Yaling and Jiao Yuying lived long in Japan, therefore argue the case litigation housing auction segmentation system requirements.

  According to the "on the implementation of<Law of succession of the people's Republic of China>Some problems of "article58Provisions, this case all successors is not in the house the actual living, two the plaintiff will be moved to Japan, the two defendants also have their own independent living residence, because of the litigation housing uninhabited so the plaintiff's claim will be assessed property hereThe auction, the auction shall be in accordance with statutory successionDivision.

Three, the defendant has the misappropriation of heritage and the fact so segmentation heritage withThe defendant does not split or a smaller share of the estate.

The defendant in an informed of any one party heir the decedent left deposit account deposit all take, legitimate inheritance act of the defendant has embezzled heritage fact and serious violation of the plaintiff Zhang Yaling's property rights and other heirs,According to "the people's Republic of China Law of succession" article24Article,As well as"The Supreme People's Court on the implementation of<Law of succession of the people's Republic of China>The views of a number of issues "Article59, the plaintiff's claim for the defendant Zhang Zhonghai shall not or less divided request should be supported.

Four, the other heirs not duty, the plaintiff's claim for the defendant or a smaller share of the estate.

The defendant Zhang Zhonghai to Jiao Yuying not duty,Although Zhang Zhonghai with his life together, but in spite of the plaintiff's daily life, often with a Steamed buns to solve the plaintiff a meal, the sick also does not bring the plaintiff to go to hospital. Zhang Yaling lived for years in Japan has a distant but had toAnd her husband separated the two places back home to take care of Jiao Yuying's life, so in the property for no income, Jiao Yuying and duty more Zhang Yaling ought to be divided, Zhang Zhonghai should not or less.

The foresaid opinions urge the court to adopt, in accordance with the law to the court rejected the plaintiff's claim, in accordance with the law to make a fair ruling.

  Yours sincerely

Beijing Haidian District people's court     

                                   Agent: Beijing law lawyer affairs

                           Lawyer.

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