Sample Recall Form for a statement of claim for foreclosure on non-residential collateral
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 Judge of Talgar district court of Almaty region .......
index 041600, Talgar city, Gagarin street No. 90. 050225@sud.kz 8 72774 2-25-49
From the defendant: gr...... IIN 700118401409. Almaty region, Talgar district,……………
rural district, village .........., St. ...., D.....
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, +7 (708) 578 57 58 ( WhatsApp).
Review of the statement of claim
on foreclosure on non-residential collateral.
In order to implement the Address of the President of the Republic of Kazakhstan to the people of Kazakhstan in 2010 "A new decade - a new economic recovery - new opportunities for Kazakhstan" and Decree of the President of the Republic of Kazakhstan dated February 1, 2010 No. 922 "On the Strategic Development Plan of the Republic of Kazakhstan until 2020" and on providing preschool education and training for children living in rural areas ..........., ............ According to the staff of the local polyclinic and the population, as of 2010 and to this day they are in dire need of pre-school educational centers where pre-school children remain without pre-school education, and their number exceeds 800 children from villages. (......... .............. state farm) who could receive pre-school education.After that, the defendant received a loan from the bank for the purchase and promotion of a Kindergarten preschool education center. "........" in accordance with the terms of the Bank Loan Agreement for № ................. dated 07/03/2007 (hereinafter referred to as the Loan Agreement), concluded between gr...... (hereinafter referred to as the Borrower) and JSC Eurasian Bank (hereinafter referred to as the Bank), the Borrower was granted a loan in the amount of 75,600,000 tenge.For the purchase of an old abandoned former kindergarten, which was mortgaged in order to ensure proper fulfillment of obligations, the Borrower under the Mortgage Agreement for №...................... dated 05/08/2008, pledged non-residential premises with a total area of 764.00 sq.m., with a land plot of 0.4144 ha, cadastral number ..............., located at: Almaty region, ................ district, ............. rural district, village ..............., St. .................., 98. Since that time, the preschool education center has been a kindergarten "..............." he started his work, but for a long time the Defendants were engaged in restoration work, since the kindergarten built in 1958 required repair and reconstruction, respectively, time and money.
In view of the global crisis that has come, which is mentioned in the annual messages to the people of the Republic of Kazakhstan by the Leader of the Nation, President of the Republic of Kazakhstan Nursultan Nazarbayev, in view of the global crisis that has come, every time he calls on everyone to be loyal in difficult times for the people, difficult times have not spared the Kindergarten ".............". Parents of children who lost their jobs began to delay payment due to the reduction. Many are unable to pay for several months and ask to wait until employment. In this regard, the Kindergarten has incurred heavy expenses where local residents (tutors, technical staff, cooks, etc.) work who need to pay their salaries.Due to the lack of financial support for the Kindergarten "............", Borrowers are forced to reduce staff, they are forced to reduce the attendance of children, and in winter, the functioning of the kindergarten became unprofitable for Borrowers, as a result of non-fulfillment of assumed obligations., borrowers owed money to the bank, but the bank always refused multiple requests to continue fulfilling its obligations, charging large penalties where all the amounts paid would have gone.Despite repeated written and oral appeals to the bank to obtain any preferential conditions and to continue fulfilling debt obligations, the bank appealed to the court to recover the amount owed in court and all the money that the borrowers' family earned went to the vilification of penalties.
By the decision of the district court no.2 Auezovsky district of Almaty dated 05/27/2011, the claims of Eurasian Bank JSC against gr ......, gr...... and gr...... for debt collection and invalidation of the mortgage agreement were partially satisfied, in solidarity with gr...... and gr...... 99,987,183 tenge was recovered in favor of JSC Eurasian Bank.On April 17, 2014, a writ of execution was issued, and to date, M.K. Myrzabaev has initiated enforcement proceedings and work is underway on enforcement proceedings. Also, an amount of 375,000 tenge has been paid to the CSI account to date.In total, the total amount of borrowers' debt to the bank is 75,225,000 tenge.To date, Borrowers are recovering their financial situation as time passes, and therefore have begun to actively participate in government programs aimed at implementing the 2010 Address of the President of the Republic of Kazakhstan to the People of Kazakhstan "A New Decade - a new Economic Recovery - New Opportunities for Kazakhstan" and the Decree of the President of the Republic of Kazakhstan dated February 1.
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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