TO THE COURT OF FIRST INSTANCE
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
VALUE OF THE CASE:
TOPIC :
DESCRIPTIONS :
1- Between our client and the defendant sports club, …./…./…. The “Professional Footballer Contract” with the start and end of …/…/… has been signed. (Annex – 1) The relevant contract was registered with the Turkish Football Federation on …./…/….
2- With the contract in question, monthly ….. TL fee to our client, …… TL per match, and …./…. in the season…. It has been decided to pay an extra fee of …… TL in case of a match or more.
3- Upon our client’s failure to pay the agreed fee based on the aforementioned contract, the Notary Public of …../…./…. dated and …. A warning letter was issued to the defendant sports club, and it was reported that the contract would be terminated unilaterally. (Annex – 2)
4- Upon the warning sent, it was reported that the contract was terminated unilaterally with the warning dated …/…/… since the defendant did not make any payments, and this termination was registered with the Turkish Football Federation. (Annex -3)
5- Despite the fact that the defendant stated in his oral interview with our sub-client that he would be fined ….. TL on the grounds of his home defeat and also disrupting the peace and discipline of the team, that he would not be paid for this reason, no notification was given to us regarding the mentioned actions of our client and Turkey No notification was made to the Football Federation either.
6- For the reasons explained above, it has become obligatory to apply to the Honorable Court for the collection of our unjustly and unjustifiably unpaid receivables.
LEGAL REASONS :
LEGAL EVIDENCE:
1- Contract concluded between the parties dated …/…/…
2nd- ../…/…. first notice of
3- ../…/…. second notice dated
4-Expert Review
CONCLUSION AND REQUEST: For the reasons stated above and without prejudice to our right to claim and litigation regarding the surplus, monthly ………. We respectfully submit and demand that it be decided to be collected from the defendant, together with the interest, and to charge the defendant’s litigation expenses and attorney’s fee. …/…/…
ATTACHMENTS:
1- Contract concluded between the parties dated …/…/…
2nd- ../…/…. first notice of
3- ../…/…. second notice dated
4-One copy of approved power of attorney
Plaintiff’s Attorney
Hunting
