不服管辖异议裁定复议申请书
    英文回答：
    Application for Reconsideration of a Determination of Lack of Personal Jurisdiction.
    Introduction.
    The applicant, [Applicant's Name], hereby applies for reconsideration of the determination of lack of personal jurisdiction issued by the court on [Date of Determination]. The applicant respectfully requests that the court reconsider its determination and find that it does have personal jurisdiction over the defendant, [Defendant's Name].
    Background.
    This case arises from a breach of contract action brought by the applicant against the defendant. The complaint alleges that the defendant breached a contract entered into between the parties in [State or Country Where Contract Was Entered Into]. The defendant fil
ed a motion to dismiss for lack of personal jurisdiction, arguing that it does not have sufficient contacts with the forum state to justify the exercise of personal jurisdiction.
    The court granted the defendant's motion, finding that the defendant's contacts with the forum state were insufficient to establish personal jurisdiction. The court noted that the defendant is not domiciled in the forum state, does not have a physical presence in the forum state, and does not regularly conduct business in the forum state. The court further found that the defendant's alleged breach of contract did not occur in the forum state.defendant
    Arguments in Support of Reconsideration.
    The applicant respectfully requests that the court reconsider its determination for the following reasons:
    The court erred in finding that the defendant's contacts with the forum state were insufficient to establish personal jurisdiction. The defendant's contacts with the forum state are more than sufficient to justify the exercise of personal jurisdiction. The defendant entere
d into a contract with the applicant in the forum state. The defendant knew that the contract would be performed in the forum state. The defendant's alleged breach of contract caused harm to the applicant in the forum state. These contacts are sufficient to establish personal jurisdiction under the long-arm statute of the forum state.
    The court erred in finding that the defendant's alleged breach of contract did not occur in the forum state. The court's finding is based on a misreading of the complaint. The complaint alleges that the defendant's breach of contract caused harm to the applicant in the forum state. This allegation is sufficient to establish that the defendant's alleged breach of contract occurred in the forum state.
    Conclusion.
    The applicant respectfully requests that the court reconsider its determination of lack of personal jurisdiction. The applicant believes that the court erred in its determination and that it does have personal jurisdiction over the defendant.
    中文回答：
    不服管辖异议裁定复议申请书。
    前言。
    申请人 [申请人姓名] 谨此申请复议法院于 [裁定日期] 作出的缺乏个人管辖权的裁定。申请人恳请法院复议其裁定并认定其对被告 [被告姓名] 具有个人管辖权。
    背景。
    本案源于申请人针对被告提起的违约诉讼。申诉状称，被告违反了双方在 [签订合同的州或国家] 签订的一份合同。被告提出驳回动议，理由是其与诉讼地没有足够的联系，不足以行使人身管辖权。

版权声明：本站内容均来自互联网，仅供演示用，请勿用于商业和其他非法用途。如果侵犯了您的权益请与我们联系QQ:729038198，我们将在24小时内删除。