Response form for a claim for termination of a housing lease and eviction agreement
To the Auezovsky district Court No. 2 of Almaty
to the judge ...........
Almaty, 050062, Kuanyshbayeva str., 44 A.
phone: +7 (727) 333-11-85
727-3260@sud.kz
From the defendants: .................
IIN ..............
gr………………
IIN ...........
gr………………
IIN .................
Address: Almaty, md. , d. , sq.
Representative by proxy:
Sarzhanov Galymzhan Turlybekovich
IIN: 850722301036.
Almaty, Medeu district,050002, Zhibek Zholy ave.,
50, Business center Block, office No. 202.
sgt.kz@mail.ru,
tel.: 8 707 (708) 578 57 58 ( WhatsApp/Viber).
Objection
on the claim for termination of the lease agreement from the state housing stock and eviction
In the proceedings of the District Court No.2 Auezovsky district has a civil case №.................. dated 05.12.2016, according to the claim of the State Department of Housing and Housing Inspection of the city of Almaty to gr.................., gr.................., gr.................. termination of the lease agreement from the state housing stock and eviction.
Response form for a claim for termination of a housing lease and eviction agreement
During the trial, the Plaintiff motivates his claims that by the Decree of the Akimat of Almaty №........... from 0... ... 201.. of the Year "On the provision of housing from the communal housing stock" ..............., for a family of five people, a two-bedroom apartment was provided from the communal housing stock of the city of Almaty at the address: Almaty, MD ".............", D........., sq . .........., taking into account the delivery of a studio apartment at: city of Almaty. ........, d........, kv..........., provided to her by the order of akim of Auezovsky district of Almaty №.......... from 07.03........... (lease agreement for housing from the state housing fund №......... dated 07/12/200 .......g.), as well as ................ In a statement dated 04/10/2015, she pledged to hand over the occupied living space within a few months, since moving and repairing takes time. We do not agree with these claims, as we consider the filed claim to be premature and not subject to satisfaction on the following grounds: By order of the akim of the Auezovsky district of Almaty №............ dated 07.03.2007 ............... There are five members of the family a person (she, her husband, 2 daughters and a son) is provided with a studio apartment at the address: Almaty, md. ..., house ..., sq.38. On the basis of the above-mentioned order from gr.................., A lease agreement has been signed for a dwelling from the state housing stock №............. dated 12.07.2007 on the provision of housing for rent at the address: Almaty, mkr....., d...., sq.38 for a family of 5 people (husband – gr..................,., daughter - gr..................,., daughter - gr..................,., son – gr..................,.). After numerous letters from Mr..................., to all instances of the executive power on the request to provide housing, the Housing Department of Almaty city has registered those in need of improved housing conditions among the socially protected segments of the population in the order of priority of the family gr.................., by Resolution of the Akimat of Almaty №.......... dated April 07, 2015 "On the provision of housing from the communal housing stock" gr..................,., for a family of five people, a two-bedroom apartment was provided from the communal housing stock of the city of Almaty at the address: Almaty, MKR "...........", D....., sq. m. 12, taking into account the delivery of a one-room apartment at the address: Almaty. mkr.., d.., kv..., provided to her by the order of the akim of the Auezovsky district of Almaty №.......... dated 07.03.2007 (lease agreement for housing from the state housing fund №.......... dated 12.07.2007), gr..................,. In a statement dated 04/10/2015, she pledged to hand over the occupied living space within a few months, since moving and repairing takes time. However, the Plaintiff did not provide an order or resolution or other document from the akim on the eviction of the gr family..................., from a one-room apartment located in Almaty. mkr ...., d...., sq.38.
Response form for a claim for termination of a housing lease and eviction agreement
According to the Statement of Claim of the KSU "Department of Housing and Housing Inspection of the city of Almaty" gr.................., after receiving an apartment located at the address of Almaty, MD "..............", d....., sq....., must hand over to the Housing Department a one-room apartment at the address: Almaty, md. .., house .., sq.38. However, the received housing is located at the address Almaty, md. ".....", d....., sq . m . …., built under the state program for socially vulnerable segments of the population, which were given to citizens from the communal housing stock on credit, gave a roll (horizontally) and today construction companies are carrying out construction work to strengthen the foundation of the house. To this day, authorized state and non-state bodies have not given a final opinion on the safety of the house for living. And we consider the claims against the Almaty City Housing and Housing Inspectorate to be premature, since in order to begin, the Almaty City Construction Department and other authorized bodies must eliminate all violations committed during the construction of the house and commission a safe house for living. Currently, living in this house is dangerous and the whole family lives in a one-room apartment in Almaty, md. ..., house ..., 38 sq.m., from which the KSU "Housing Management and Housing Inspection of Almaty" is trying to deprive and evict the family of gr.................., classified as socially vulnerable segments of the population (affected by nuclear tests at the Semipalatinsk nuclear Power Plant polygon). If, after all, house no., mkr "............" they recognize the family of gr as an emergency (and this is not surprising).................., There's nowhere to go. Based on the above,
I ASK THE COURT:
To refuse to satisfy the Plaintiff's claims for termination of the lease agreement from the state housing stock and eviction.
Sincerely, Proxy Representative: _________________/ Sarzhanov G.T. "___"_____________20__ the year.
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