.TO THE MINISTER’S JURISDICTION
…….
CLAIM:…….
ATTORNEY: …….
DEFENDANT:…….
SUBJECT : Percentage of your monthly receivable of …………………-TL, without prejudice to our right to claim and litigation regarding the surplus. It is a request for a decision to be collected together with the interest.
EXPLANATIONS: 1-My client company manufactures ready mixed concrete. The defendant, on the other hand, has undertaken the construction of the expansion of the ……….. factory. For this reason, in order to get the ready mixed concrete needed from our company, ……. made the contract dated. In accordance with this contract, ready-mixed concrete was purchased from our company on various dates.
2-According to paragraph 3 of the attached contract; Payments will be made by 30/60/90-day postdated checks. Likewise, according to the 5th article of the contract; 12% monthly interest will be calculated for the receivables transferred to the current account because they are not paid. According to Article 9 of the Convention, Kocaeli Courts are authorized in disputes.
3-As it can be understood from the attached current account table, the defendant party is late in payments, and the sum of these delays is ……. and to this ……. When VAT is added, the other party’s contractual debt is …….
EVIDENCE: Contract, current account statement, company records, expert examination, other legal evidence.
ANSWER TIME: 10 Days
RESULT OF THE REQUEST: With the above-mentioned reasons and without prejudice to our right to demand and litigation regarding the surplus……. We request that our receivable be collected from the defendant together with the monthly ……. interest to be calculated from the date of the lawsuit, that the cost of the trial be charged to the defendant, and that the other party attorney fee be decided on our behalf as an Attorney in accordance with the 164/last paragraph of the Law No. 1136, amended by Law No. 4667.
ATTORNEY’S ATTORNEY
