TO CONSUMER COURT JUDGE
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT: It includes our request to collect the prepaid ……… TL from the defendant with the cancellation of the timeshare contract dated …/…/… dated between the parties.
DESCRIPTIONS :
1-) Between our client and the defendant on …/…/…, ……. A timeshare sales contract for TL has been drawn up. (ANNEX 1)
2-) Over the sales contract between the parties …. Although months have passed, the title deed registration of the property has not been transferred to our client yet. However, as per the contract made, the delivery date is …./…/… and our client cannot benefit from the timeshare since it is not transferred upon the title deed registration.
3-) Our client, with a warning letter dated …/…/… due to the defendant’s breach of the contract, claimed that he had exercised his right to withdraw from the contract and requested the cancellation of the contract and the return of the TL that he had paid in advance, but the warning sent by the defendant party was not responded to. payment has not been made. (Annex – 2)
4-) Due to the defendant’s breach of the timeshare agreement, it has become obligatory to apply to your court for the refund of the prepaid TL.
LEGAL REASONS: 634 S. K. m. 57, 58, 59, 60, 61, 62, 63, 64, 65.
LEGAL EVIDENCE: 1-) Timeshare sales contract dated …./…/…
2-) Warning dated …/…/…
3-) Expert Review.
CONCLUSION AND REQUEST: Due to the defendant’s breach of the timeshare contract due to the reasons explained above, the cancellation of the contract, the collection of the prepaid ….. TL, together with the legal interest to be accrued from the date of the lawsuit, and the judgment of the litigation expenses and attorney’s fee to be charged to the other party, We respectfully request on behalf of our client. …/ …/ …
Plaintiff’s Attorney
Lawyer
ATTACHMENTS:
1-) Timeshare sales contract dated …./…/…
2-) Warning dated …/…/…
3-) Expert Review.
4-) One copy of approved power of attorney.
