Request For Collection Of Commission Receivable, Deprived Profit And Equalization Compensation Arising From The Wrongful Termination Of Agency Agreement
TO THE JUDGE OF THE … COURT
DEFENDANT :
TC No:
ADDRESS :
ATTORNEY :
ADDRESS :
PLAINTIFF:
TC No:
ADDRESS :
SUBJECT : It consists of the submission of our petition including our request for the collection of the commission receivable arising from the unfair termination of the Agency Agreement, together with the deprived profit and equalization compensation.
OUR OPENING STATEMENT
1-) An agency agreement was signed between our client and the defendant on …/…/…., which imposes obligations on both parties. Our client started insurance agency activity with this contract. The term of the contract was agreed to be … years and it was agreed that the contract will be extended for … years unless the insurance company notifies that the contract will not be extended until … days before the end of the term. (Annex – Contract Sample)
2-) Although the contract was extended for a period of …/…/…. before the expiry date of the contract, …/…/…., without informing our client, our client’s online connection was disconnected and his activities were blocked, and then our client was notified that the contract was terminated with a notice dated …/…/… dated …/…/…/… issued at the … Notary Public.
3-) As can be understood from Article 7 of the contract, unfair termination conditions have occurred and our client has a commission receivable from the defendant. In addition, due to the unfair termination, our client’s commercial reputation has been damaged and has suffered profit deprivation. In case of unfair termination of the contract, since it is a requirement of equity for the insurance company to pay our client an appropriate equalization compensation for the customer circle left by our client’s agent to the insurance company, it has become necessary to file this petition with the request to decide to collect the commission receivable, deprived profit and equalization compensation from the defendant together with interest.
LEGAL GROUNDS : 6102 S. Code Art. 121, 122
LEGAL EVIDENCE : Agency agreement dated …/…/…/…dated …/…/…/…dated notice, commercial books, expert examination, oath
CONCLUSION AND REQUEST : For the reasons explained above, we respectfully request on behalf of our client to collect the commission receivable of ….TL, the deprived profit of … TL and the equalization compensation of … TL from the defendant together with interest, and to decide to charge the trial expenses and attorney fees to the other party. …/…/…
ANNEXES: 1-) Agency agreement dated …/…/…/…
2-) …/…/… dated …/…/..,
3-) One approved power of attorney sample
Counsel for the Plaintiff
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