Current location - Recipe Complete Network - Catering franchise - Seek a civil complaint. June, 2005 165438+ 10/6 Du Moumou and Zhang Moumou (manager of Anxx Company) and Wang Moumou (wife of Zhang Moumou in Anmou Community). ...
Seek a civil complaint. June, 2005 165438+ 10/6 Du Moumou and Zhang Moumou (manager of Anxx Company) and Wang Moumou (wife of Zhang Moumou in Anmou Community). ...
Plaintiff in civil litigation: Du Xx, male, XX years old, Han nationality, native of Shaanxi Province, manager of XX Hotel, living in XX Building, XX City, XX District, Xi City. Authorized Agent: Liang XX, lawyer of An XX Law Firm.

Defendant Zhang XX, male, XX years old, Han nationality, from An City, Shaanxi Province, department manager of An XX Company, living in XX Street, XX District, Xi City.

Defendant Wang XX, female, XX years old, Han nationality, native of Shaanxi Province, cadre of sub-district office of XX District, with the same address as above.

ask

1. Request the court to order the defendants Zhang×××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××××

2. Request the court to order the two defendants to compensate the economic losses of 6.5438+0.25 million yuan;

3. The litigation expenses shall be borne by the two defendants.

Facts and reasons

1999 165438+1October16. The original defendant and the defendant signed a house lease agreement, stipulating that the defendants Zhang XX and Wang XX would lease their 200-square-meter building on the third floor of a brick-concrete structure at No.38 Huancheng South Road in this city and its ancillary power distribution and water supply and drainage facilities to the plaintiff Du XX for catering and entertainment business. The plaintiff must pay the annual rent in one lump sum before June 30th of each year. 165438+. If it is delayed for 30 days, the defendant has the right to take back the house. Before the expiration of the lease term, the plaintiff has the right to transfer his restaurant to others, but should inform the defendant before the transfer, and the defendant and the transferee will sign a separate house lease agreement under the condition that the rent remains unchanged; Before the expiration of the lease term, the defendant shall not terminate the agreement or raise the rent. If the defendant terminates the agreement, he should compensate the plaintiff for four years' rent. If the plaintiff terminates the agreement, the rent paid by the plaintiff will not be refunded, and the house decoration will be owned by the defendant.

After the agreement was signed, both the original defendant and the defendant fulfilled their obligations according to the contract. The defendant delivered the house to the plaintiff, and the plaintiff paid the defendant an annual rent of 75,000 yuan. Subsequently, the plaintiff renovated the house into a restaurant. In June 2000, 165438+ 10, the lease expired for one year, and the plaintiff paid 75,000 yuan as agreed. On June 5438+February 65438+February 9, 2000, the plaintiff published an advertisement for restaurant transfer in Xi Evening News. At the beginning of 200 1 year 1 month, the plaintiff transferred the restaurant to a third person, Li XXX, and informed the defendant of the transfer before the transfer. After the transfer, the defendant refused to sign another lease agreement with the transferee Li XX as agreed in the agreement, and obstructed its operation, which made Li XX unable to operate, and forced him to quit the restaurant at the end of June of the same year 165438+ 10. During this period, the plaintiff lost 75,000 yuan in rent due to the defendant's breach of contract, resulting in a business loss of 50,000 yuan.

In view of the above facts, the plaintiff believes that the above behavior of the defendant has seriously violated the contract agreed by both parties, causing economic losses to the plaintiff and damaging the legitimate rights and interests of the plaintiff, and should bear the liability for breach of contract and compensate for the losses. According to the provisions of Article 107 of the Contract Law and Article 108 of the Civil Procedure Law, we request your hospital to matter of justice according to law.

Name and address of witnesses, evidence and sources of evidence

1. Original lease agreement;

2. The plaintiff's payment voucher;

3. Description of the defendant's obstruction of business operation.

Xi beilin district people's court.

Prosecutor: Du XX

200165438+February 5.

Attachment: 1 2 copies of the certificate; 2. 3 copies of documentary evidence.