How to draw up a cassation appeal to arbitration: help from a lawyer

Cassation appeal against the decision of the arbitration court

At the very beginning, any investigation and analysis takes place in an ordinary court, according to standard patterns, when a representative of the law makes his verdict, based on arguments and evidence.

Next, one of the parties may put forward a request to re-examine the case to the same court in order to correct the situation and achieve a different result. You need to make such a request before the verdict has not yet been approved and has not acquired rights. If this time the matter is a fiasco, there is a third opportunity to try to rectify the situation, by going to higher authorities.

A cassation appeal to the Arbitration Court of the Ural District will help with this if the matter concerns appealing decisions in our region, but not directly, but through the court, which is obliged to transfer all documents in three working days.

Writing a complaint to the Chairman of the Supreme Court

The main reason for refusing to accept a cassation appeal is its non-compliance with the norms, form and rules established at the legislative level. In practice, there are often situations when refusal to accept an application is unfounded. An effective tool that allows you to continue the fight to resolve a judicial issue in favor of the client is to draw up a motivated complaint that meets all formal requirements. At the legislative level, there is no procedure for drawing up and filing such a complaint with the Supreme Court. But this fact is not a significant obstacle for the party to protect the violated rights.

On a note! If the cassation appeal is rejected by the Supreme Court, the applicant should contact the Chairman. In this case, it is necessary to additionally (repeatedly) pay the state duty (in accordance with the Tax Code of the Russian Federation).

You can complain when, in your cassation appeal to the Supreme Court, you have received a refusal to transfer the complaint for consideration at a court hearing.

1) you have passed the first stage of cassation (at AS IOC)

2) then you applied to the second stage of cassation (to the RF Armed Forces)

3) your complaint was “rejected” by a single judge of the Supreme Court without submitting it for consideration

4) now the time has come to complain to the Chairman of the Supreme Court about the refused determination.

Deadline for filing a cassation appeal to the arbitration court

An important point will be the deadline for filing a cassation appeal in the arbitration process; it is strictly regulated - a maximum of two months after the appealed decision enters into legal force. If you were late and did not meet this time period, the complaint will still be accepted, but only if the premises on which this happened are considered valid by the court. In this case, the cassation appeal in the arbitration case is accepted for analysis, but no later than 6 months from the date of its entry into force.

Cassation instance

A cassation appeal in a civil case is filed with a cassation court of general jurisdiction. But through the court of first instance. This means that the addressee must be specified as the cassation court, and the documents must be sent to the court that made the decision.

There are 9 cassation courts of general jurisdiction in Russia. Where to file a cassation appeal is always indicated in the judicial act of the appellate instance. If necessary, you can use Article 23.1 of the Federal Constitutional Law “On the Judicial System of the Russian Federation.” This article contains an indication of which region belongs to which cassation court.

Sometimes a cassation appeal is filed directly with the Supreme Court of the Russian Federation (Article 390.4 of the Code of Civil Procedure of the Russian Federation). Including in the case when the cassation authority considered the cassation appeal. That is, in essence, a participant in the case has the opportunity to file a cassation appeal twice.

How to file a cassation appeal against an arbitration court decision?

There is a certain procedure for filing a cassation appeal to the arbitration court. The application must be submitted in writing. There is another option - fill out a special form on the official website of the court. The one who submits the act signs on it, or this is done by an authorized representative, if there is one.

Such an act must necessarily contain the following facts:

name of the court receiving the complaint;
personal data of the applicant;
number order of the case, result of the verdict;
subject of dispute;
an indication of a violation of substantive and procedural law, which led to a miscarriage of justice in the case;
a person’s request to cancel all decisions taken or leave one of the judicial acts in force.

Regardless of the subject of the dispute in the first instance: whether it is the reclaiming of property by the owner from someone else’s illegal possession or the collection of debt under a contract, a cassation appeal is subject to a fixed fee of three thousand rubles.

It should be noted that failure to comply with the requirements provided for in the legislation entails the return of the filed complaint, however, after eliminating the shortcomings, this complaint can be re-filed to the cassation court.

Cassation appeal in a civil case

To the Judicial Collegium for Civil Cases of the Supreme Court of the Russian Federation

121260, Moscow, st. Povarskaya, 15, Applicant of the cassation appeal (Defendant and Plaintiff in the counterclaim) Limited Liability Company "Zaychik", Moscow, Semenovskaya St., 1 A from the Applicant / representative of the Defendant LLC "Zaychik": lawyer Chernov Sergey Vitalievich, Moscow Interdistrict Bar Association Address: Moscow, st. 7th Parkovaya, 24.

Defendant: Durynda Daria Ivanovna Moscow, st. Telyachikh Nezhnosti, 1, apt. 1

State duty paid in the amount of 3 thousand rubles

Cassation appeal against the Determination of the judicial panel for civil cases of the Moscow City Court dated December 16, 2015 in case No. 33-33333/15 and the Determination of the judge of the Moscow City Court dated March 20, 2016 No. 4g/4-4444/2016

The Perovsky District Court of Moscow was processing civil case No. 2-3333, initiated at the request of citizen Durynda D.I., who was previously the founder and general director of Durynda LLC (a company engaged in leasing real estate), with requirement for recognition of a lease agreement for non-residential premises located at the address: Moscow, st. Lazurny Promises, 30, terminated, collection of debt under the contract and collection of compensation for utility bills.

Zaychik LLC also filed a statement of claim with the said court demanding registration in accordance with Art. 165 of the Civil Code of the Russian Federation of the additional agreement dated October 21, 2013 on increasing the rented space to the Lease Agreement for non-residential premises dated April 20, 2006 with an area of 171.4 sq.m. and additions dated October 30, 2013 on changes in rent calculations from November 2013 to the Lease Agreement for non-residential premises dated April 20, 2006, previously signed with Durynda LLC, since, according to paragraph 1 of Article 617 of the Civil Code of the Russian Federation, the transfer of ownership to property leased to another person is not grounds for changing or terminating the lease agreement.

Considering that both claims were between the same parties and since there was a mutual connection between the claims and their joint consideration should have led to a faster and more correct consideration of disputes, the Court combined these cases into one proceeding, assigning the number to civil proceedings No. 2- 3333. Durynda D.I.. as the legal successor of the lessor Durynda LLC became the Plaintiff in the case, and Zaichik LLC became the Defendant and Plaintiff in the counterclaim, respectively.

By its decision on July 15, 2015, the Perovsky District Court of Moscow satisfied the demands of Durynda D.I. partially: recognized the lease agreement for non-residential premises as terminated, but refused to collect compensation for payment of utility bills from the Company. Accordingly, the claim of Zaichik LLC was denied. The company Zaichik LLC, not agreeing with this decision, appealed to the Judicial Collegium for Civil Cases of the Moscow City Court with a request to cancel this decision and make a new one - to satisfy the demands of Zaichik LLC stated in the court of first instance. The Moscow City Court, by its appeal ruling dated November 5, 2015, having considered the case in its entirety at its own discretion, and not just the Company’s complaint, without notifying the Company about it, partially satisfied the Company’s appeal: the decision of the Perovsky District Court of Moscow regarding the claims Duryndy D.I. – canceled the termination of the lease agreement, but at the same time satisfied the demand of Durynda D.I. on the collection from LLC "Zajchik" of debt for utility bills in the amount of 229,435.00 rubles, interest for the use of other people's funds in the amount of 14,186.53 rubles, leaving in force the expenses for a representative of 15,000 rubles. He refused to satisfy the Company's demands for state registration of additional agreements to the real estate lease agreement.

The company Zaichik LLC believes that the appellate court, when considering the Company’s appeal, issued a Determination on the basis of: unacceptable evidence - oral testimony of Durynda D.I. herself, that the tenant allegedly compensated for the payment of utility bills in the absence of other, including written evidence (invoices, bank statements, checks, receipts, acts, letters, etc.); in violation of Part 4 of Art. 67 Code of Civil Procedure of the Russian Federation and parts 4 of Art. 198 of the Code of Civil Procedure of the Russian Federation, which provides for the obligation of the court to reflect in the decision, which provides the reasons why some evidence was accepted as a means of substantiating the court’s conclusions, and other evidence was rejected by the court, as well as the reasons why some evidence was given preference over others, nevertheless in violation of the specified articles of the Code of Civil Procedure of the Russian Federation, he did not evaluate important written evidence:

1. Letter dated June 25, 2014, coming from the party in the case - Lessor Durynda D.I.. to the tenant - Vostok LLC, which discloses the nature of the relationship under the lease agreement for non-residential premises in terms of payment of funds for the use of utilities. (attached)

2. The fact that on the day of signing the main lease agreement for non-residential premises on April 20, 2006, legal entities signed an Agreement on changing the conditions dated April 20, 2006 (Appendix No. 1 to the Agreement), not yet registered in Rossreestr, was left unattended, in which, in addition to the condition of increasing the rented area to 117.1 sq.m., was mentioned in clause 3 of clause 2 of the Agreement on payment by the Tenant for utilities, and payment was to be made separately from rental payments for invoices issued by the Landlord Durynda LLC actual consumption by the store. (the cassation court on sheet 3 of the Determination agrees with this fact).

According to paragraph 1 of Article 56 of the Code of Civil Procedure of the Russian Federation, “each party must prove the circumstances to which it refers as the basis for its claims...” Lessor LLC “Durynda” - legal successor Durynda D.I. did not issue a single invoice and did not provide evidence of payment for utilities by the Tenant!!! AND ACCORDINGLY DID NOT PROVIDE THE COURT WITH ANY EVIDENCE OF PAYMENT OF utility bills by Zaichik LLC for all these years.

In the court of first instance, the court examined the Agreement on changing the conditions dated April 20, 2006 (Appendix No. 1 to the Agreement) (sheet No. 3 of the decision of the Perovsky District Court), which indicated the conditions on the method of payment of utility bills by the Tenant only according to those issued by the Landlord LLC " Durynda" bills for actual consumption. The landlord did not PROVIDE THE COURT WITH ANY EVIDENCE that Durynda LLC had paid utility bills for all these years. Also, the Landlord did not present to the court a single unpaid utility bill issued to the Tenant. According to paragraph 1 of Article 452 of the Civil Code of the Russian Federation, an agreement to amend or terminate a contract is made in the same form as the contract, unless otherwise follows from the law, other legal acts, contract or customs.

At the same time, paragraph 3 of Article 438 of the Civil Code of the Russian Federation provides that the person who received the offer, within the period established for its acceptance, takes actions to fulfill the terms of the contract specified in it (shipment of goods, provision of services, performance of work, payment of the appropriate amount, etc.) .p.) is considered acceptance, unless otherwise provided by law, other legal acts or specified in the offer.

In the relations between the parties, the Tenant LLC "Zajchik" from April 21, 2006 until this case came into force in November 2015 paid only rental payments to the Lessor LLC "Durynda" - legal successor Durynda D.I., which accepted these payments, that is accepted this payment without paying utility bills without any claims.

That is, the rules specified in paragraph 3 of Article 438 of the Civil Code of the Russian Federation also apply to changes in the contract. It is necessary to take into account that according to the additional agreement signed on April 20, 2011 to the Lease Agreement for non-residential premises dated April 20, 2006, the term under the lease agreement was extended until September 20, 2014. And already on March 31, 2014, the parties, the Lessor Durynda LLC and the tenant Zaichik LLC, signed a reconciliation report, according to which they have no financial claims against each other. This document indicates Durynda LLC’s acceptance of the relationship specifically regarding payment for the use of the premises without including additional payments.

Since this dispute arose initially between legal entities, the Applicant LLC “Zajchik” provides judicial and arbitration practice on this issue. (Such an example is given in the Resolution of the Presidium of the Supreme Arbitration Court of the Russian Federation dated February 4, 1997 N 3895/95).

There is also a legal position of civil law scholars and judges of the Supreme Arbitration Court of the Russian Federation on this issue, set out in the publication “Problems of the development of private law: Collection of articles for the anniversary of Vladimir Saurseevich Em” (ed. E.A. Sukhanov, N.V. Kozlova) (“Statute”, 2011) “In this regard, the commission of implied actions under certain conditions can be considered as consent to amend a contract concluded in writing, since Implicit actions act as a law-altering legal fact.”

The same position is set out in the Resolution of the Presidium of the Supreme Arbitration Court of the Russian Federation No. 4905/11 dated September 6, 2011). Similar rules are set out in paragraph 5 of the information letter of the Presidium of the Supreme Arbitration Court of the Russian Federation dated May 5, 1997 No. 14 “Review of the practice of resolving disputes related to the conclusion, amendment and termination of contracts”, according to which the commission of implicative actions can be considered under certain conditions as consent to the introduction changes to a contract concluded in writing.

In some cases, the performance of implicative actions by a party may be considered as a way of entering into an agreement to amend the contract. No pre-trial procedure for resolving a dispute regarding payment of utility bills Durynda LLC - legal successor Durynda D.I. didn't declare. This also indicates that there is no debt to pay utility bills.

Accordingly, Durynda LLC filed such counterclaims for the first time with the Moscow Arbitration Court in December 2014, only after Zaichik LLC filed its claims against Durynda LLC with a request to the arbitration court to carry out state registration of additional .agreements to the lease agreement for non-residential premises in accordance with Article 165 of the Civil Code of the Russian Federation, however, the specified case No. A40-00000/2014 in 2015 was terminated due to the liquidation of IREN LLC and the transfer of the disputed property to N.G. Filippova, as an individual .

The applicant LLC “Zajchik” discloses the text of the letter from LLC “Durynda”, which was mentioned above under No. 1 and has not been assessed in any way in any of the three courts: Letter of offer from LLC “Durynda” to the Tenant dated June 25, 2014 No. 2/2, in which the general director of Durynda LLC, Durynda D.I., made a proposal to consider the possibility of making changes to the lease agreement “retrospectively”. In this letter Durynda D.I. requested the following changes to the Agreement regarding past periods of time:

Thus, for LLC “Zajchik” it was proposed to: 1. Establish a rent of 120 thousand rubles from April 1, 2014. 2. Establish that the cost of operating and utilities, including electricity, is not included in the rent and is determined by calculation based on the results of each month of lease based on the actual volume of consumption by the Tenant of operating, utilities and electricity in the premises. As stated above, no court assessed this letter with the draft additional agreement in violation of Part 4 of Art. 67 Code of Civil Procedure of the Russian Federation and parts 4 of Art. 198 of the Code of Civil Procedure of the Russian Federation was not given in his judicial act!!!! Although the Landlord, by this letter, expressed his will to shift the responsibility for paying utility bills, to which the tenant refused. Leaving without evaluation the Reconciliation Report and the said offer letter, which actually simultaneously confirms the acceptance (consent) that payment of utility bills is the responsibility of the owner himself, and not the Tenant, led to the issuance of an illegal judicial act by the appellate authority, which entered into legal force. On sheet 4 of the appeal ruling, the court indicated “that at the court hearing it was established that before the dispute arose between the parties in April 2014, the terms of the agreement were fulfilled by the parties taking into account additional agreement No. 1, namely, the plaintiff was paid rent in the amount of $2,500 monthly, and the costs of paying for utilities were paid by the Tenant (case file 220). Recognizing this fact as established, the panel of judges proceeds from the fact that on the reverse side of the copy of additional agreement No. 1 dated April 20, 2006 there are records of the payment of funds by Durynda D.I. in the amount of 2,500 US dollars monthly, the defendant does not deny that the rent was changed and the plaintiff was effectively paid the equivalent of $2,500.”

As can be seen above, the court made a contradictory judgment, in the first sentence it included both rent and utilities in the $2,500, and in the second sentence it stated that the rent was paid in an amount equivalent to $2,500. In addition, utility costs cannot be constant all year round, since in winter costs increase significantly due to consumption of heat and electricity!!! Therefore, on this basis, there is nothing confirmed that the tenant paid utility bills.

Therefore, the conclusions of the appellate court regarding the imposition of the obligation to pay for utilities on the Tenant (SHEET 6 of the Definitions) are far-fetched, without taking into account the written evidence available in the case materials.

The Court further states, “in accordance with this norm, taking into account the subsequent behavior of the parties who signed an agreement to change the conditions, which are annex to Lease Agreement No. 1 dated April 20, 2006, as well as the subsequent actions of Zaichik LLC, which paid until 2014 year, utilities to the plaintiff, as follows from the explanations of Durynda D.I., the panel comes to the conclusion that the valid common will of the parties is established to conclude a lease agreement on the terms of payment for utilities at the expense of the tenant, which corresponds to the logic of any lessor who is not interested in bearing irrecoverable losses associated with the consumption of utilities by a tenant who is not interested in optimizing them.”

However, I repeat that in these legal relations, oral explanations from a party without other evidence are unacceptable. In fact, the court, by its judicial act, created new legal relations that the parties did not strive for. The applicant provides for information a number of judicial acts that refute the erroneous position of the appellate court that landlords never undertake obligations to pay for utilities, which indicate that the obligation to pay utility bills lies with the lessor: - Resolution 15 of the Arbitration Court of Appeal dated November 2, 2015 N 15AP-14795/2015 - Resolution of the AS of the URAL DISTRICT dated May 14, 2015 N F09-1203/15 in case N A76-24125/2013 - REVIEW OF JUDICIAL PRACTICE OF THE SUPREME COURT OF THE RUSSIAN FEDERATION N 2 (2015 ) dated June 26, 2015 QUESTION 5. Who - the landlord or the tenant of non-residential premises - is responsible for paying for utilities in the absence of a properly executed agreement with the person providing them (utility service provider, resource supply organization)? ANSWER. The owner bears the burden of maintaining the property he owns, unless otherwise provided by law or agreement (Article 210 of the Civil Code of the Russian Federation). By adopting this court decision, the appellate court actually violated the stability of civil circulation. Significant procedural violations. The appellate court, when considering the case, deviated from the principle of equality of the parties, without any grounds, making a decision not only within the framework of the filed appeal, but on the requirements that the Plaintiff Durynda D.I.. set out in her statement of claim. Thus, the Court of Appeal actually “took” side in the case of Durynda D.I.., considered the case formally, the cassant made this conclusion based on the following: In accordance with paragraph 24 of the Resolution of the Plenum of the Supreme Court of the Russian Federation dated June 19, 2012 No. 13 “On the Application by Courts of the Rules of Civil Procedure Legislation Governing Proceedings in the Court of Appeal”, in accordance with parts 1, 2 of Article 327.1 of the Code of Civil Procedure of the Russian Federation, the court of appeal verifies the legality and validity of the court decision of the first instance court only in the appealed part based on the arguments set out in appeals, presentations and objections regarding them. At the same time, the appellate court, on the basis of paragraph two of part 2 of Article 327.1 of the Code of Civil Procedure of the Russian Federation, has the right, in the interests of legality, to check the appealed court decision in full, going beyond the requirements set out in the appeal, presentation, and without being bound by the arguments of the complaint, presentation. If the appellate court has come to the conclusion that it is necessary to check the appealed court ruling of the first instance court in full, the appeal ruling in accordance with paragraph 6 of part 2 of Article 329 of the Code of Civil Procedure of the Russian Federation must contain the reasons why the appellate court came to this conclusion. Taking this into account in detail, the appellate court during the trial did not even notify the parties of the decision made to consider the case “in full”, that is, not to be limited to the scope of the complaint, thereby violating the right of Durynda LLC to appropriately provide evidence and arguments within the framework of the entire case, and not just complaints, although the Society raised the issues indicated below at the court hearing. It is also necessary to take into account that already from May 5, 2008, the parties signed an Addendum to Appendix No. 1 to the lease agreement, according to which the rent from May 5, 2008 was 87,000 rubles and again was paid without additional utility payments. A cassation appeal was filed with the Presidium of the Moscow City Court to review the appeal ruling of the Moscow City Court dated November 6, 2015, which entered into legal force, in connection with significant violations by the court of substantive and (procedural) law that influenced the outcome of the case (Article 387 of the Code of Civil Procedure of the Russian Federation).

The Court of Cassation judge found on sheet 3 of the Determination that “the tenant was obliged to pay the landlord the equivalent of $2,500. Payment for utilities is made separately, for what is actually consumed by the store according to the invoices issued by the landlord. And he also noted the reconciliation act dated March 31, 2014, signed by the parties, according to which the parties have no claims, therefore Filippova was refused to collect rental payments.” According to the Applicant LLC "Zajchik", the court erroneously indicated that Filippova did not provide evidence of arrears in payment of rental payments, which could have arisen accordingly before its signing, i.e. on March 31, 2014, since they did not exist during this period. On sheet 4, the cassation judge believes that “the arguments of the cassation appeal come down to disagreement with the stated conclusions of the judicial panel, the assessment of the factual circumstances of the case, are based on an incorrect interpretation of the rules of substantive law, contain an explanation of the circumstances of the present case outlining the position of the defendant in the initial claim regarding the dispute that has arisen and his subjective opinion about the correctness of his resolution. However, the contested appellate ruling was made on the basis of the evidence collected in the case in its entirety. The applicant’s disagreement with this assessment is aimed at re-evaluating the evidence, which, by virtue of Chapter 41 of the Code of Civil Procedure of the Russian Federation, is not within the powers of the cassation court.” The applicant does not agree with such conclusions, since a number of the above evidence was left without evaluation at all, a number of circumstances indicated above and reflected in judicial acts - the appellate and cassation instances are generally contradictory and not confirmed by anything, in connection with which it is impossible to talk about legality adopted court decisions. Based on the above and guided by Art. Art. 376 - 378 of the Civil Procedure Code of the Russian Federation, I ask:

I ASK: 1. To request from the Perovsky District Court of Moscow civil case No. 2-33333/2015 at the suit of citizen Durynda D.I. to Zaychik LLC for termination of the lease agreement for non-residential premises and recovery of compensation for utility bills and assign the case for consideration on the merits in the cassation court. 2. CANCEL the appeal ruling of the Moscow City Court dated November 6, 2015 and the ruling of the Judge of the Moscow City Court G.A. Avanesova. dated May 18, 2021 No. 4g/4-4444/2016 regarding the collection of debt to pay utility bills in favor of Durynda D.I. in the amount of 229,435.00 rubles, interest for the use of other people’s funds in the amount of 14,186.53 rubles, expenses for a representative 15,000 rubles; 3. Uphold the decision of the Perovsky District Court of Moscow regarding the refusal to collect arrears of rent and utilities and make a new decision or send the case for a new trial to the appropriate court.

Appendix: 1. Receipt for payment of the state fee 2. Copy of the decision of the Perovsky District Court of Moscow dated July 15, 2015. 3. Copy of the appeal ruling of the judicial panel for civil cases of the Moscow City Court dated November 6, 2015. 4. Copy of Determination No. 4g/4-4444/2016 dated May 18, 2021 5. Power of attorney confirming the powers of the applicant’s representative 6. Copy of Appendix No. 1 dated April 20, 2006 7. Copy of letter dated June 25, 2014 No. b/n s draft additional agreement to the Lease Agreement. 8.Copy of the Addendum to the lease agreement dated May 5, 2008. 9. Copy of the Reconciliation Report dated March 31, 2014 10. Copy of Minutes No. 1 dated October 21, 2005 on the appointment of the General Director 11. Copy of Minutes No. 7 dated May 27, 2014 on the extension of the powers of the General Director 12. Extract from the Unified State Register of Legal Entities

General Director of Zaichik LLC
M.I. Thoughtful

The procedure for considering a cassation appeal in an arbitration court

This complaint is considered in the court of the arbitration district, in a court session in the presence of the parties.

It should be taken into account that the Supreme Court, when accepting for review an act - a cassation appeal against an appellate ruling of an arbitration court, does not analyze the factual details of the case. His task is to find out for what reason and whether the court issued such a verdict legally.

Based on the results of the consideration, the court makes one of the following decisions:

about the refusal to satisfy the complaint, in this case the decisions are not subject to change or cancellation;
about the cancellation of judicial acts and the issuance of a new act, about what services are available for collecting receivables, read the link;
on the cancellation of acts and transfer of the case for a new trial;
on leaving in force one of the previously adopted acts;
to terminate the proceedings.

Additionally, it should be taken into account that in a number of cases, for example, if there is reasonable confidence that if a positive decision is made on the cassation appeal, the other party will not be able to return the funds received under the canceled judicial act, it is possible, at the request of the party, to initiate a suspension of the execution of the judicial act, in In a number of cases, for this suspension it is necessary to deposit the amount recovered by the court; in such circumstances, this request is granted unconditionally.

Thus, a cassation appeal in the arbitration process is a guarantee for any person of fairness, confidence that the final result is truly legal and legitimate.

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ASK:

To cancel the decision of the Moscow Arbitration Court dated July 5, 20__ on the claim of ZAO “V.” to the Federal State Institution "O.", Resolution of the Ninth Arbitration Court of Appeal dated 04.10.20__, to send the case for a new trial to the Moscow Arbitration Court in a different composition.

Please notify the legal bureau “Moscow Legal” of the date and time of the court hearing, Moscow, st. Maroseyka, 2/15,

Application:

power of attorney for a representative (1 letter);
documents on sending additions and material to the Defendant (1 sheet);
invoice, act, invoice for June 20__ (7 years);
invoice, act, invoice for July 20__ (7 years);
invoice, act, invoice for August 20__ (7 years);
invoice, act, invoice for September 20__ (7 years);
invoice, act, invoice for October 20__ (3 sheets);
invoice, act, invoice for November 20__ (7 years);
invoice, act, invoice for December 20__ (3 years);
statement of reconciliation of calculations as of February 21, 2008 (5 sheets);
letter of gratitude dated 10/07/2008 (1 sheet);
contract dated May 31, 20__ for maintenance (6 sheets);
contract for the provision of maintenance services dated 08/01/20__ (3 p.)
connection act dated February 10, 2009 (1 sheet);
licenses of ZAO V. (for 7 years);
network maintenance agreement dated April 10, 20__ (for 7 years);
agreement on connection and inter-operator interaction dated November 1, 2008 (29 pages);
act of acceptance of communication structures (6 sheets);
communication quality check protocol dated November 28, 20__ (2 pages)
contract for installation of a communication line dated January 23, 20__ (7 years);
agreement for the provision of assessment services dated 09/13/20__ (10 sheets);
contract for services for servicing the video-on-demand network dated 09/01/2009 (8 sheets);
network maintenance agreement dated July 1, 2009 (6 pages);
network maintenance agreement dated 08/01/2009 (9 pages);
contract for installation of communication lines dated August 12, 2009 (8 sheets);
copies of articles from T. magazines and "6."
copy of the decision of the Moscow Arbitration Court dated 07/05/20__
copy of the decision of the Ninth Arbitration Court of Appeal dated 10/04/20__
extract from the Unified State Register of Legal Entities (7 pages) (https://msk-legal.ru)

Representative of the Plaintiff by proxy ______________________________/Khoruzhenko A.S./ 04.12.20__

Lawyer for drafting cassation in arbitration in Yekaterinburg

How to proceed if, after the trial is over, people remain dissatisfied with the verdict? In this case, it is recommended to demand a repetition of the hearing with the cancellation of the decisions of the first instance and the rulings of the appeal board in the case.

Our lawyer for arbitration disputes at the Law Office “Katsailidi and Partners” will help you not only with the appeal, but will also write a response to the cassation appeal to the arbitration court if opponents in the case have taken up the appeal. Call today!