The form of the response to the Statement of claim for the recovery of alimony for the maintenance of the spouse
Auezovsky district Court No. 2 of Almaty
To the judge ................
Republic of Kazakhstan, Almaty, 050062,
Kuanyshbayeva St., 44 "A".
From the Defendant: gr. ………
IIN: ................
050000, Almaty, md. ...., D......
+7 (702) … … …
...........@gmail.com
Representative by proxy:
Sarzhanov Galymzhan Turlybekovich
IIN: 850722301036.
Almaty, Medeu district,050002, Zhibek Zholy ave.,
50, office 202, Business center Block.
info@zakonpravo.kz / www.zakonpravo.kz
+ 7 (708) 578 57 58.
Feedback
on a statement of claim for the recovery of alimony for the maintenance of a spouse
Q, is there a civil case in your case №........... dated 30.10.201_ according to the claim of gr. ........., to gr. ........., on the recovery of alimony for the maintenance of a spouse, who justifies her claims that on August 31, 2012, she married the defendant and lived with the defendant jointly up to 5 years old. They have a child under three years old from their marriage, who was born on 02/27/2017. She is currently not working because she is on leave to care for her child. She does not have a source of income for the maintenance of an underage child, as well as for accommodation. The Plaintiff does not have the opportunity to earn money because he constantly takes care of the child.
The Defendant voluntarily does not provide financial assistance for the maintenance of the child and for the maintenance of the Plaintiff. We do not agree with the plaintiff's arguments, since when studying how a person works on social networks, we found that the Plaintiff actively works and earns on Instagram social networks, where more than 76,600 citizens of our country are subscribers (subscribers are customers) and has 699 publications of goods, which indicates a high passability / marketability of goods (you can make sure that following the link ............... ). The plaintiff manufactures and sells Instagram on social media .............. to beauty salons throughout the territories of the Republic of Kazakhstan, and in the contacts, the Plaintiff indicates his personal number 8 707 ... .... ..., according to which I, rana, corresponded with the Plaintiff on the Whatsapp application (as evidenced by the screenshots in the applications). On average, such online sales generate revenues of about one million tenge per month. In online trading, goods are paid for through bank accounts in second-tier Banks. In connection with this, we request that a court order be issued to require second-tier banks to issue statements on current accounts of cash receipts.
Also, the Plaintiff's arguments that the Defendant does not voluntarily provide financial assistance do not correspond to reality, since the defendant and I personally have repeatedly been asked to return home, where my spouse and mother-in-law live. In January 201_, the Plaintiff, without any compulsion or psychological or moral pressure, temporarily went to her home. At that time, the defendant thought that the Plaintiff had postpartum psychosis and took her to her parents for a while, however, after the expiration of time, the Plaintiff refused to return, demanding that the defendant leave his mother (pensioner) who is dependent on the defendant and lives separately with the plaintiff.
However, it was not possible to convince the Plaintiff of her selfish/immoral thoughts. However, the defendant did not worry about the security of his wife and baby, since when they lived together, they accumulated money in a joint marriage of about 7,000,000 tenge, which the Plaintiff deposited in her name before leaving an open account with Kazkommertsbank JSC, and accordingly took it with her and on which she still lives comfortably.
The plaintiff's arguments that she does not have the means to pay for a living are not true, since if you look at her personal Instagram page (you can click on the link and make sure ..............) The plaintiff can be seen how luxuriously she lives (see screenshots of the Instagram page in the applications) where the Plaintiff undergoes spa treatments, visits expensive restaurants and entertainment venues in the most expensive SPA salons located in Esentai Mall. Thus, the Plaintiff's arguments that she is currently unemployed and has no source of income and there is no way to earn money for a living wage in connection with caring for a child are not confirmed.
The form of the response to the Statement of claim for the recovery of alimony for the maintenance of the spouse
Also in the Statement of Claim, the Plaintiff indicated that the defendant has the opportunity to pay alimony as he works for an LLP ............ And at the University ................, where the alleged permanent earnings amount to 400,000 tenge and asks the Court to collect from the defendant a fixed sum of 100,000 tenge until the child reaches 3 years of age. Dear Court, the Plaintiff's arguments that the defendant's permanent earnings amount to 400,000 tenge are erroneous, since the defendant never earned such money during marriage, we do not know where the Plaintiff's fantasies come from. According to the official salary certificate issued by the LLP ........... The defendant actually works for an LLP .............. (a small business entity) in the position of Director, and the monthly income is 108,473 tenge, of which 10,847 tenge are transferred to pension contributions, 7,317 tenge are transferred to Individual Income Tax. In total, the Defendant receives an amount of 90,309 tenge per month.
The Plaintiff's arguments that the Defendant works in parallel at the University ................... not true (as evidenced by the help in the applications) since the defendant and Rane did not work at the university. Defendant wound up at the University to get a teaching internship in the community
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