COURT
Prosecutor:
Attorney:
DEFENDANT:
SUBJECT: Request for Determination of Voluntary Insurance.
INSTRUCTIONS
1-) My client …, with social security number SSKit, is also registered at the address … My client … has been paying premiums to the. Voluntary Insurance unit of the Insurance Directorate since /…/.
2-) My client applied for retirement to the defendant institution with a petition dated… And registered under number. The institution stated in a reply letter dated… And registered under number that they had no such file. My client’s request was rejected, and therefore he is not considered a voluntary insured person.
3-) The defendant institution initially accepted my client’s request to become a Voluntary Insured Person and collected all premium payments for the period between …/…/… and …/…/…, without issuing any warning that the premiums paid were invalid.
4-) The … Insurance Directorate collected the unpaid premiums retroactively, together with the date and receipt, with a printed “Voluntary Insurance Premium Collection Receipt” including the late payment surcharge. For these reasons, it has become necessary for us to file a lawsuit to determine my client’s voluntary insurance, whose retirement request was not accepted.
LEGAL GROUNDS: 506 PK m. 85 and related legislation.
LEGAL EVIDENCE: PSK records, receipts, expert examination, witness statements, and
other evidence.
CONCLUSION AND SUMMARY
For the reasons explained above, I respectfully request that your High Court rule that the premiums paid as of /…/… are Voluntary Insurance Premiums and that my client is a Voluntary Insured as of /…//…, order the defendant to pay the costs of the proceedings, and render a decision. …/…/…
Attorney for the Plaintiff