Pre-trial claim of the Insurance Company for recovery of insurance payments
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Insurance company JSC NSC Almaty md. Almagul, 15a
BIN 960 440 000 716 info@nsk.kz +7 727 258-18-00
from: ....... Alibek Aliuli IIN .......... Almaty MD. ............ The house is 69 sq. m.6 (ID 6196176,
contract number 202343568)
Representative by proxy:
Law Company Zakon i Pravo LLP
BIN 190240029071 Almaty, 79/71 Abylai Khan ave., office 304.
info@zakonpravo.kz / www.zakonpravo.kz
+ 7 727 971 78 58; +7 708 971 78 58.
PRE-TRIAL CLAIM
08/28/2020 .......... AA (hereinafter referred to as the client) has entered into a contract for Kia Sorento motor transport insurance GRNZ ........ IUB 02, built in 2020, black, VIN-XWWPH812DL0006163 (hereinafter referred to as the vehicle) with JSC Oil Insurance Company (NSC hereinafter referred to as the insurer). In accordance with art . 3, the Law of the Republic of Kazakhstan of the Republic of Kazakhstan "On compulsory insurance of civil liability of vehicle owners" (hereinafter referred to as the Law) is the object of compulsory insurance of civil liability of vehicle owners (hereinafter referred to as the Law). - compulsory liability insurance of vehicle owners) is the property interest of the insured person related to his obligation, established by the civil legislation of the Republic of Kazakhstan, to compensate for damage caused to life, health and (or) property of third parties as a result of the operation of the vehicle as a source of increased danger. 06/21/2021 ....... AA, driving the above-mentioned car in the village of Isaevo, along Suyunbaya Street, heading east, hit a concrete ditch. As a result of a traffic accident (hereinafter referred to as the accident), mechanical damage was inflicted on the above-mentioned vehicle and material damage was caused. On 07/19/2021, this fact was considered in the interdistrict administrative court of the Karasai district of the Almaty region and a decision was made to terminate the administrative case in the case of ........ AA for the absence of an administrative offense 610 of the Administrative Code of the Kyrgyz Republic (case number No.1954-21-00-3/3302).
Pre-trial claim of an insurance company for recovery of insurance payments
Kia Sorento GRNZ brand vehicle .......... The IUB 02, which suffered material damage, is a 2020 car manufactured by Mitsubishi Center South LLP under warranty. According to the defect act to the order along No. 0000003876 dated 06/30/2021 conducted by Mitsubishi Center South LLP, the cost of repair and restoration work of the vehicle is 4,752,785 tenge. Mitsubishi Center South LLP is the official dealer of Kia Sorento cars in the Republic of Kazakhstan. On July 13, 2021, the insurer provided the client with an assessment report in the amount of 1,300,000 tenge. Which the client does not agree with. On 08/10/2021, the client conducted an independent evaluation of the above-mentioned vehicle. According to the assessment of Bakyt Assessment Group LLP, the cost of damage to the vehicle is 4,835,249 tenge. According to paragraph 1 of Article 113 of the Civil Procedure Code of the Republic of Kazakhstan, at the request of the party in whose favor the decision was made, the court awards, on the other hand, the costs incurred by her to pay for the assistance of a representative (several representatives) involved in the process.
152 and 279 of the Civil Procedure Code of the Republic of Kazakhstan and Article 402 of the Civil Code of the Republic of Kazakhstan, stipulating that the judge returns the statement of claim, and the court leaves the statement of claim without consideration if the plaintiff fails to comply with the pre-trial procedure established by law for this category of cases, the mandatory procedure for preliminary pre-trial dispute resolution and the possibility of this procedure is not lost and preserved. We hereby suggest that you voluntarily pay the client funds in the amount of 4,835,249 tenge. If you do not pay the funds in the amount of 4,835,249 tenge, we reserve the right to apply to the court on this issue. As well as the recovery of the amount of material (damages and penalties, Article 351 of the Civil Code of the Republic of Kazakhstan) in the amount of 4,835,249 tenge, as well as representative services in the amount of 800,000 tenge. We hope for your mutual understanding.
Sincerely, Proxy Representative: ________/ Nurlanov N.N.. "___"______2021 G.
Attention!
Law and Law Law Law draws your attention to the fact that this document is basic and does not always meet the requirements of a particular situation. Our lawyers are ready to assist you in legal advice, drawing up any legal document suitable for your situation.
For more information, please contact a Lawyer / Attorney by phone: +7 (708) 971-78-58; +7 (700) 978 5755, +7 (700) 978 5085.
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