染雾民事答辩状英语篇一
To the Honorable Judge,
RE: Civil Case No. [Case Number]
[Plaintiff's Name] v. [Defendant's Name]
DEFENDANT'S ANSWER AND DEFENSES
I, [Defendant's Name], the defendant in the above-mentioned civil case, hereby submit my answer and defenses to the allegations made by the plaintiff, [Plaintiff's Name]. I deny all the claims made against me and provide the following defenses:
1. Lack of Sufficient Evidence:
The plaintiff has failed to provide sufficient evidence to support their claims. Without concrete evidence, their allegations lack merit and should be dismissed.
2. Failure to State a Claim:
The plaintiff has not clearly stated the legal basis for their claims. Their allegations are vague and do not meet the requirements for a valid legal claim. Therefore, their case should be dismissed.
3. Contributory Negligence:
The plaintiff's own negligence or actions contributed to the alleged harm or damages. As a result, the plaintiff should bear partial or full responsibility for the consequences they are claiming.
4. Statute of Limitations:
The plaintiff filed this case after the expiration of the applicable statute of limitations. As such, their claims are time-barred, and the case should be dismissed on this ground.
5. Lack of Standing:
The plaintiff does not have the legal standing to bring this case against me. They have not established any direct or personal interest in the matter at hand, and therefore, their claims should be dismissed.
6. Failure to Mitigate Damages:
The plaintiff has not taken reasonable steps to mitigate their damages. They had the opportunity to minimize their losses or prevent further harm but failed to do so. Their failure to mitigate should reduce or eliminate any damages awarded.
7. Unclean Hands:
The plaintiff has engaged in improper or unethical conduct related to the matter at hand. Their actions demonstrate a lack of good faith and fairness, making their claims unworthy of consideration.
8. Lack of Causation:
There is no causal connection between the plaintiff's allegations and the alleged harm or damages. The plaintiff has not provided sufficient evidence to demonstrate that my actions directly caused the harm they are claiming.
In conclusion, I deny all the allegations made by the plaintiff and request that this Honorable Court dismiss their claims against me. I believe that the evidence and defenses presented above clearly establish my innocence and lack of liability in this matter.
Respectfully submitted,
[Defendant's Name]
Date: [Date]
民事答辩状英语 篇三
民事答辩状英语
答辩人：××人民医院
住址：××市××路七号
Respondent： ××× People's Hospital
Address： No 7, ××Road, ×× City
因×××要求×××人民医院人身损害赔偿一案，现提出答辩意见如下：
The following answer is hereby given to the claim of ××× for compensation by the ××× People's Hospital for personal injuries：
1.答辩人与×××之间不存在直接的合同关系，答辩人1998年6月10日与××第二建筑安装工程公司订立了一份口头合同，由××第二建筑安装工程公司负责把答辩人的一个高压电表柜拆除，×××是受××第二建筑安装工程公司的委托来拆除高压电表柜的，与答辩人之间不存在直接合同关系。
1. The respondent does not have a direct contractual relationship with ×××. The respondent entered into an oral contract with ×× No 2 Construction and Installation Company on June 10, 1998, whereby ×× No 2 Construction and Installation Company shall be responsible for removing the high-voltage meter cabinet. ××× was engaged in removing the high-voltage meter cabinet as entrusted by ×× No 2 Construction and Installation Company and therefore has no direct contractual relationship with the respondent.
2.××的伤害赔偿应由××二建筑安装工程公司负责，其一，根据我国法律和有关司法解释规定，××第二建筑安装工程公司对其职工在履行合同的范围内
其三，受××第二建筑安装工程公司委 托的×××在拆除高压电表柜的过程中，存在着严重违反操作程序的行为，未尽一个电工应尽的注意。
2. The liabilities for compensating ×× for the damage shall be born by ×× No 2 Construction and Installation Company for the following reasons. Firstly, pursuant to PRC laws and relevant judicial interpretations, ×× No 2 Construction and Installation Company shall be liable for any injuries suffered by its employees to the extent of the contract performance. The injuries of ××× was not caused by anything other than the object of the contract. Thirdly, ×××, who was entrusted by ×× No 2 Construction and Installation Company, seriously violated the operational procedure in removing the high-voltage meter cabinet and failed to pay due attention thereto.
3.答辩人对×××伤害赔偿不应承担责任。
根据我国《民法通则》的规定，从事高度危险作业的`人致他人损害的，应负赔偿责任。
而本案中答辩人与××第二建筑安装工程公司订有合同，高度危险来源已通过合同合法地转移给 ××第二建筑安装工程公司。
××第二建筑安装工程公司成为该危险作业物的主体，××在操作过程中受到伤害，这是××第二建筑安装工程公司在履行合同过程中，合同客体造成自己员工的伤害行为，与答辩人无关。
3. The respondent shall not be liable for compensating the injuries of ×××. In accordance with the General Principles of the Civil Law, any person engaged in highly dangerous operation shall be liable for compensation in the event of any damages. In this case, however, the respondent entered into a contract with ×× No 2 Construction and Installation Company, whereby the source of high danger shifted to ×× No 2 Construction and Installation Company legitimately. ×× No 2 Construction and Installation Company became the subject of the dangerous operation, and therefore any damages caused in the contract performance by ×× No 2 Construction and Installation Company has no connection with the respondent.
综上所述，×××人民医院为不适合被告，请贵院依法驳回原告起诉。
By reason of the foregoing, ××× People's Court is not legible for becoming the defendant. We hereby request the court to reject the plaintiff's action according to law.
此致
××市中级人民法院
To：
×× City Intermediate People's Court
答辩人：×××人民医院
Respondent： ××× People's Court
日期：
Date：
相关阅读：
法律英语常见句子汇总
一、Trial 审判
1.A case is only authority for what it actually decides.
判例只能用作实际判决事项的法律依据。
2.A judgment msut be impartial.
判决必须公正。
3.All legal systems have a rule that a judicial determination of a case is final.
所有法律制度的规则都是将司法判作为最终手段。
4.Before trial the defendant may move to dismiss the case on the ground that the facts alleged do not constitute a crime.
审判前，被告方可以所控事实不构成犯罪为自由权，要求撤销案件。
5.Do not wait for the last judgment, it takes place everyday.
审判永无终止，每天都在发生。
6.He was acquitted of the crime.
他被宣判无罪。
7.He was committed for trial in the Central Criminal Court.
他被带到中央刑事法院受审。
8.He was sentenced to five years, but should serve only three with remission.
他被判了五年徒刑，但减刑后仅服刑三年。
9.He was sentenced to two periods of years in prison, the sentences to run concurrently.
他被判处两个两年的徒刑，该判决合执行。
10.He was tried for murder and sentenced to life imprisonment.
他因谋杀而受审并被判处终生监禁。
