The form of the response to the Statement of Claim for the termination of the lease agreement from the state housing stock and eviction
Attention! The Law and Law Law Company draws your attention to the fact that this document is basic and does not always meet the requirements of a specific situation. Our lawyers are ready to assist you in drafting any legal document that suits your situation. For more information, please contact lawyer Kenesbek Islam by phone; +7 (708) 971-78-58; +7 (727) 971-78-58.
To the Auezovsky district Court No. 2 of Almaty to the judge ...........
Almaty, 050062, Kuanyshbayeva St. 44 A. tel. +7 (727) 333−11-85 727-3260@sud.kz
From the defendants: ................. IIN .............. gr………………
IIN ...........
gr.................. IIN ................. Address: Almaty, md. , d. , sq.
Proxy representative: Galymzhan Turlybekovich Sarzhanov
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
for a claim for termination of a tenancy agreement from the state housing fund 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.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" ..............., A family of five people was provided
The form of the response to the Statement of Claim for the termination of the lease agreement from the state housing stock and eviction
two-bedroom apartment from the communal housing stock of the city of Almaty at the address: Almaty, MD ".............", D........., sq. m. .........., 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 for the following reasons:By order of akim of Auezovsky district of Almaty №............ dated 07.03.2007 ............... a family of five people (she, her husband, 2 daughters and a son) is provided with a studio apartment at the address: Almaty, mkr. ..., 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....., ...., 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 three-room apartment was provided from
municipal housing fund of the city of Almaty at the address: Almaty, MD "...........", d...., sq. 12, taking into account the delivery of a studio apartment at the address: Almaty. md.., d.., sq..., provided to her by order of Akim Auezovsky Almaty city district №.......... 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 tmunicipal housing fund of the city of Almaty at the address: Almaty, MD "...........", d...., . 12, taking into account the delivery of a studio apartment at the address: Almaty. md.., d.., sq..., provided to her by order of Akim Auezovsky Almaty city district №.......... 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 PlaintifHowever, 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. According to the Statement of Claim of the KSU "Department of Housing and Housing Inspection of the city of Almaty" gr.................., after receiving the apartment located at the address of Almaty, MKR "..............", 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 located at Almaty, md. "....", d....., sq...., built under the state program for socially vulnerable segments of the population, which were given to citizens from the communal housing stock on credit, has given a roll (horizontally) and is currently under construction The 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 of 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 ..., hous ..., 38 sq.m., from which the KSU "Housing Management and Housing Inspection of Almaty" is trying to deprive and evimily
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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