The indictment template -- personal mortgage purchase case

Plaintiff.  Bank Xiamen branch of Limited by Share Ltd

Address:

Head.

The defendant: (female, the Han nationality, identity card number:)

Address:

Contact telephone number:

The defendant two: (male, the Han nationality, identity card number: )

Address:

Contact telephone number:

The three: Xiamen  Real estate Co., Ltd.

Address:

Legal representative:

Contact telephone number: 

 

The claim:

1,  To order the defendant to the plaintiff, the defendant in a two principal repayment   Yuan and interest (including compound interest and impose a punitive interest), temporary plan to The date for   Yuan, up to the loan contract, loan interest rate broke surface50%To the actual payment date.

2,  Order the defendant, the defendant to the plaintiff, a two pay the plaintiff lawyers have lawyers fees  Element.

3,  To order the defendant to three the defendant, the defendant to the plaintiff two debt bear joint and several liability.

4,  The collateral that the plaintiff has the right to request the people's court to dispose of the defendant, the defendant provided (a twoSite in Xiamen City Real estate), and has the right to dispose of the priority to be repaid.

5,  To order the defendant to be borne by the cost of litigation.

 

Facts and reasons:

The defendant, the defendant to the plaintiff two housing mortgage loan applications, commitment to the purchase of new property for the loan collateral, and ensure all the family property to guarantee the application property. Subsequently, the date, the three defendants and plaintiffs signed and numbered : No. Bank of individual housing loan contract "(hereinafter referred to as the" loan contract "), the provisions of the contract:1The plaintiff, defendant, the defendant provided two RMB Million yuan, the borrowing period from2007Date2017Date;2, loan interest, principal repayment methods, calculation basis and standards impose a punitive interest, compound interest;3Advance loan conditions, and the liability for breach of contract;4The defendant, the defendant, twoSite in Xiamen City Real estate collateral for the loan contract debt and mortgage real estate mortgage statement, not people and raising families necessities, mortgage guarantee not to justify, mortgagee shall exercise the mortgage right of defense;5,The defendant to provide joint liability guarantee for the defendant, the defendant three two under the loan contract debt;6For the realization of creditor's rights, the plaintiff expenses (including attorneys fees) by three for the defendant. Then, the original defendant in the mortgage registration authority for registration of the mortgaged property.

The plaintiff of the loans from year month day in full. The defendant, the defendant two not in accordance with the provisions of a contract for loan of money to fulfill debt service obligations, by July, the defendant, the defendant has the repayment of two yuan, the contract amounted to The principal element, overdue days has reached the day, his behavior constituted a breach of contract. The three defendant, the defendant in the two default is not the plaintiff shall bear joint and several liability guarantee responsibility.

Based on the above reasons, in order to maintain their own rights and interests, the special litigation to your school, please the expensive hospital judges as v..

 

Yours sincerely

Xiamen Siming District People's court

 

 

                                 Plaintiff: Bank Xiamen branch of Limited by Share Ltd

 

2011Years Day