TO THE COURT OF FIRST INSTANCE
FILE NUMBER:
PLAINTIFF:
ATTORNEY:
DEFENDANT:
SUBJECT: Correction of the title of the defendant company and submission of our statements as per the interim decision.
DESCRIPTIONS
1- Since the defendant … A.Ş changed its title after the lawsuit was filed, we amend the title of the defendant company as … A.Ş.
2- Due to the damage, our Company suffered a total of … -Turkish Lira material loss. As stated in the discovery documents, …-TL material, …Turkish Lira from the labor and vehicle expenses, … -Turkish Lira after deducting the collected material expenses, and 18% … VAT is added to the total …-Turkish Lira total material and labor amount, and the total loss is in Turkish Lira. calculated.
We will receive a total of … Turkish Lira,
Damage date … from … to partial payment date %…. advance interest=…Turkish Lira has been used and the …Turkish Lira paid on … has been deducted from interest in accordance with Article 84 of the Code of Obligations, and … Turkish Lira interest receivable remains.
A lawsuit has been filed for the collection of a total of … TL, of which … Turkish Lira is the principal receivable and … Turkish Lira is the interest, as of the date of payment.
3- In accordance with the law, the VAT rate to be applied is 18%, and we objected to the account made at a different rate in the determination report.
4- It is clear that the objections of the defendant regarding duty and hostility are not valid, and the decision of the Court of Cassation … Civil Chamber, numbered …/… E and …/… K., which we submitted to the Court file, reveals the groundlessness of the objections.
CONCLUSION AND CLAIM: Due to the reasons I have stated above, I respectfully request that the title of the defendant company be corrected and that our case be approved.
Plaintiff’s Attorney
