TO Mr. JUDICIARY
MEASURE IS DEMANDED
Plaintiff:
ATTORNEY: …….
DEFENDANT:…….
CASE: Litigation
SUBJECT : Our client ……. It is the demand for the collection of the receivable together with the legal interest.
EXPLANATIONS:1-Our client sold his passenger car to the defendant on …….. According to the written agreement between them, the defendant ……. prepaid, the remainder……. For this purpose, they have agreed on deferred payment. If one of the installments is not paid, the other will be deemed to be due. In addition, the defendant also consented to our client’s taking precautionary measure and precautionary attachment without any security in case of non-payment, pursuant to the contract.
2-Our client delivered the vehicle to the defendant on the promised day and gave the sale from the notary public. He also delivered all kinds of receipts that the vehicle does not owe taxes and stamps to the defendant.
3-Defendant ……., which he should give to our client ……. He did not pay the installment amounting to the same amount and did not respond to our client’s numerous calls.
4- Our client heard that the defendant took the vehicle to the auto market to sell it, and later learned that the defendant deceived a few more people in this way and did not pay their money.
5-Our client is required to pay ……. It wants the receivable of the amount of the customer to be paid together with the interest to be accrued as of the date of the installment. Because the first installment is not paid in accordance with the contract, the second installment is considered to be due. In addition, in order to prevent our client from being a victim later on, and in order to prevent the transfer of the license plate of the vehicle he transferred to the defendant to third parties, he wants measures to be taken -without requesting any collateral from my client as per the contract.
LEGAL REASONS: Relevant provisions of the UK
EVIDENCE: Dated sales contract, witnesses and other legal evidence.
ANSWER TIME: 10 days.
RESULT OF THE REQUEST: For the reasons explained, our client is from the defendant ……. Together with the legal interest to be calculated from the installment dates of the first receivable, it is transferred from the defendant to the defendant in order that our client does not become a victim later on. In order to prevent the transfer of the license plate numbered vehicle to the license plate of the vehicle to third parties, we request that measures be taken -without requesting any collateral from my client as per the contract-, that the costs of the trial be loaded to the defendant, and that the other party’s attorney’s fee be decided on our behalf as an Attorney in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by the Law No. 4667.
ATTORNEY
