Action Of Debt
………….. TO THE CIVIL COURT OF FIRST INSTANCE
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
VALUE OF THE CASE : …….. – TL
SUBJECT : Our request for the collection of ……..TL receivable together with monthly ………% interest.
OUR EXPLANATIONS
1.The client …. signed a contract dated …/…/…/…to buy ……. from the defendant. However, the client suffered damages due to the non-delivery of the …….. purchased from the defendant …/…./……..
2. According to the article …. of the contract in question between the parties; payments will be made in ……. As can be understood from the attached current account table, the client has made its payments regularly on the specified dates.
3.However, the defendant party has not fulfilled its responsibilities as required by this contract, and although a notice was drawn by us on …/…/…/…date …/…/…with the … notary public’s … docket numbered notice in order to fulfill the performances subject to the contract, no concrete step has been taken by the defendant party to fulfill the performances.
4. In the light of the matters explained above, it is necessary to file this lawsuit.
EVIDENCE :
1. The contract dated …/…/…/… concluded between the parties,
2. Invoices and documents for all repairs made until the date of the lawsuit
3. Current account statement,
4. … Notary Public’s notice dated …/…/… dated …/…/… with journal number ..,
5. Expert examination,
6. Commercial books and records,
7. All kinds of other evidence.
CONCLUSION AND REQUEST : For the reasons stated and without prejudice to our right to claim and sue for more, due to the non-delivery of the …… that my client purchased from the defendant …. TL receivable from the defendant together with monthly … interest to be calculated from the date of the lawsuit, we respectfully request and demand that the judicial expenses and attorney’s fee be decided to be charged to the defendant.
Plaintiff Attorney
………………..
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