Check Cancellation Lawsuit Petition
TO THE HONORABLE PRESIDENCY OF THE PRINCIPAL COMMERCIAL COURT OF ANTALYA
REQUEST FOR PRECAUTIONARY MEASURES
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT : No Adversary
SUBJECT : Our petition including our request for the cancellation of the check dated …/…./…… due to loss.
EXPLANATIONS
1. The client company sells technology products. For this purpose, the checks listed below, which were received from its customers and endorsed by the official of the client company, were stolen by breaking the window of the vehicle of the client company personnel. Due to the theft that occurred in the vehicle of our client’s personnel, the report kept by Levent police station and photographs of the crime scene are attached to our petition.
List of Stolen Checks
X Bank X Branch, X Date, XXXX Amount, XX Check drawn on XXX, XXX Serial Numbered Check
X Bank X Branch, X Date, XXXX Amount, XX Check drawn on XXX, XXX Serial Numbered Check
X Bank X Branch, X Date, XXXX Amount, XX Check drawn on XXX, XXX Serial Numbered Check
X Bank X Branch, X Date, XXXX Amount, XX Check drawn on XXX, XXX Serial Numbered Check
X Bank X Branch, X Date, XXXX Amount, XX Check drawn on XXX, XXX Serial Numbered Check
2. Since these stolen checks were drawn by companies with a high commercial reputation in the market, since the client company also has endorsement and the checks are not yet due, there is a possibility of collecting the equivalent of the checks from the bank when the checks are due.
3. In order to prevent the collection of the checks from the bank and to prevent damage to our client and our client’s customers who draw the check, it has become necessary to file this lawsuit for the cancellation of the check, including the imposition of a payment ban for precautionary purposes.
EVIDENCE : Bank records, check photocopies, witnesses, police reports, and other legal evidence.
CONCLUSION and REQUEST : For the reasons briefly explained above and to be taken into consideration by your court ex officio, we hereby request that our lawsuit be accepted and that a payment ban be imposed immediately in order to prevent the payment of the checks belonging to our client, the photocopies of which are attached and the list of which we have submitted in our lawsuit petition, and that the said check be canceled at the end of the lawsuit.
Plaintiff Attorney
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