Receivable Lawsuit Petition Sample
…. TO THE HONORABLE JUDGE
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : It is the request to decide to collect the …………………-TL receivable together with the monthly interest of …….% ……., without prejudice to our right to claim and sue for the excess.
EXPLANATIONS : 1-My client company manufactures ready-mixed concrete. The defendant party, on the other hand, has undertaken the expansion construction of the ……….. factory. For this reason, it has made the attached contract dated ……. to buy the ready-mixed concrete it needs from our company. Pursuant to this contract, he purchased ready-mixed concrete from our company on various dates.
2-According to paragraph 3 of the attached contract; payments will be made by 30/60/90-day post-dated checks. Likewise, according to Article 5 of the contract; 12% monthly interest will be calculated for the receivables transferred to the current account due to non-payment. According to Article 9 of the agreement, Kocaeli Courts are authorized in case of disputes.
3-As can be understood from the attached current account table, the defendant party has been late in payments, and the total of these delays is ……., and when ……. When VAT is added to this, the debt of the other party under the contract is ……..
EVIDENCE: Contract, current account table, company records, expert examination, other legal evidence.
RESPONSE TIME : 10 Days
CONCLUSION OF THE REQUEST: For the reasons stated above and without prejudice to our right to claim and sue for more, we request that our ……. receivable be collected from the defendant together with the monthly ……. interest to be calculated from the date of the lawsuit, that the trial expenses be charged to the defendant, and that the counterparty attorney fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
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