recovery of the cost of work under the Contract

[Адвокат]

To the Arbitration Court ______________________
________________________________________

Claimant: _________________________________
(name or full name

________________________________________
individual entrepreneur, address)

Phone fax ____________,
Email mail ______________________________
Representative __________________________

Defendant: ______________________________
(name or full name

________________________________________
individual entrepreneur, address)

Phone fax ____________,
Email mail ______________________________
Representative __________________________

Cost of claim: ________________________ rub.

SUGGESTED STATEMENT
for the recovery of the cost of work under the Contract

In accordance with the Contract Agreement N _______ of "__" ______ ____, the plaintiff (contractor) fully completed the work on the ______ stage. The plaintiff notified the defendant (customer) about the work in advance and after the defendant (customer) did not show up for the acceptance of the work, he sent the act of delivery and acceptance of work (original N _______ from "__" _____ ____ g.). However, the defendant (customer) did not sign the act, and did not submit any motivated objections.
Preliminary tests accepted by the defendant with a positive result.
The interim acts of acceptance of work by the defendant were signed without comment.
The defendant was filed a claim N ___ of "__" _______ ____, in response to which he indicated that the contractor had not completed the following works: ______________.
We consider the refusal to satisfy the claim unreasonable, because the specified works are not provided for by the Agreement (provided by the next stage).
Based on the foregoing, guided by Article.Article. 702, 709 of the Civil Code of the Russian Federation, Article 27, 106, 110, 125, 126 of the APK of the Russian Federation,

I BEG:

1. To recover from the defendant the cost of completed but not paid work under the Contract in the amount of _________ rubles. and costs of state duty in the amount of ___________ rubles.
2. Reimburse the plaintiff's legal expenses for representing his interests in court.

Applications:
1. Copy of agreement N ___ from "___" _________ ____
2. A copy of the work schedule.
3. Copy of act N ___ from "__" __________ ____
4. A copy of the claim.
5. A copy of the receipt for sending it.
6. A copy of the response to the claim.
7. Payment order on transfer of state duty.
8. A document confirming receipt of a copy of the claim by the defendant.
9. The power of attorney of the representative, if the statement of claim is signed by the representative.
10. A copy of the certificate of state registration as a legal entity or individual entrepreneur.
11. The calculation of the value of the claim.
Head of organization (representative) ________________________
Source: https://www.efremov-partners.ru/documents/index.php?SECTION_ID=155&ELEMENT_ID=1432

 

[Матушкин Андрей Николаевич]

Thank!