TO THE COURT OF FIRST INSTANCE
APPLICANT : ……………………….
ATTORNEY: Atty.
DEFENDANT : ……………………….
VALUE OF THE CASE: …….. – TL
SUBJECT : It is our request to decide on the collection of ……..TL receivables together with ………% monthly interest.
OUR EXPLANATIONS
1. Client .… from the defendant ……. signed a contract dated …/…/… to receive However, the delivery of …….. that he received from the defendant …/…./……. The client suffered damages as a result of his failure to do so.
2. The contract between the parties in question …. According to article no. Payments will be made as ……. As it can be understood from the attached current account table, the client made the payments regularly on the specified dates.
3. However, the defendant party did not fulfill its responsibilities in accordance with this contract, and although we were warned by the notary public on …/…/… in order to fulfill the obligations subject to the contract, with the notice no.
4. In the light of the issues explained above, it was necessary to open this case.
EVIDENCE:
1. Contract dated …/…/… concluded between the parties,
2. Invoices and documents for all repairs made up to the date of the lawsuit
3. Current account statement,
4. Notary public’s notice dated …/…/… dated … journal no.
5. Expert examination,
6. Commercial books and records,
7. All kinds of other evidence.
CONCLUSION AND REQUEST: Due to the stated reasons and without prejudice to our right to demand and litigation regarding the surplus, due to the failure to deliver the …… that my client received from the defendant …. We respectfully submit and demand that our TL receivable be collected from the defendant together with the monthly … interest to be calculated from the date of the lawsuit, and that the trial expenses and attorney’s fee be charged to the defendant.
Plaintiff’s Attorney
Lawyer
