TO THE JUDICIARY OF THE COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : Our petition includes our request for the collection of commission receivables arising from the Unjust Termination of the Agency Agreement, deprived profit and equalization compensation.
DESCRIPTIONS :
1-) Between our client and the defendant …/…/…. An agency agreement was signed on the date of (Annex-1) Our client started his insurance agency activities with this contract. The duration of the contract was determined as … years, and it was decided that the contract would be extended for … years unless the insurance company warned that the contract would not be extended until … days before the end of the period.
2-) The expiry date of the contract is …/…/…. Despite the fact that the contract was extended for another … year, since no notice was given to our client in this regard before the date of …/…/…. Our client’s online connection was blocked without informing our client on the date of the date, and then our client was informed that the contract was terminated with a warning letter dated …/…/… dated …/…/… issued by the … Notary Public.
3-) Our client has a commission from the defendant. In addition, due to the wrongful termination, our client’s commercial reputation was damaged and he was deprived of profit. In case the contract is terminated unfairly, our client is obliged to file this lawsuit with the request of a decision to collect the commission receivable, deprived profit and equalization compensation from the defendant together with the interests of the deprived profit and equalization compensation, since the insurance company pays an appropriate equalization (portfolio) compensation to our client for the customer circle left by our client to the insurance company. born.
LEGAL REASONS: 6102 S. K. m. 121, 122
LEGAL EVIDENCE: Agency agreement dated …/…/… Warning letter dated …/…/…, commercial books, expert examination, oath
CONCLUSION AND REQUEST: Due to the reasons explained above, …TL to be increased in case the commission receivable is calculated by expert experts to be excessive (to be increased when it is possible to determine it fully and precisely) … TL to be increased in case the deprived profit and when it is calculated by expert experts (full and to be increased as soon as it is possible to be determined definitively) … we respectfully request on behalf of our client to decide on the collection of … TL equalization compensation together with the interests (it can change according to the request), the litigation expenses and the attorney’s fee to be charged to the other party. …/…/…
APPENDIX: 1-) Agency contract dated …/…/…
2-) Warning dated …/…/…,
3-) One copy of approved power of attorney
Plaintiff’s Attorney
Lawyer
