Civil Court Of First Instance Petition For Reply To Reply
TO THE HONOURABLE JUDGE OF ISTANBUL …. CIVIL LAW COURT
FILE NO: 2013/……….Easasas
WHO MADE A DECLARATION
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
ATTORNEYS :…….
SUBJECT:
This is our petition regarding the petition of the plaintiff’s attorney dated ………………………….
DISCLOSURES
It is not possible to accept the petition dated ……………. submitted by the plaintiff to the Honourable Court and received by us on …………………. Namely
1- In its petition, the plaintiff claims that the client has been given its products on consignment for the purpose of sale in order to avoid paying taxes in bad faith. We do not accept the plaintiff’s allegations of tax evasion against the client. As we have explained in detail in our previous statements, there has never been any commercial relationship between the parties that should be recorded in the commercial book. This situation is also understood from the fact that the plaintiff cannot show any document proving that there is a commercial relationship between the parties.
The plaintiff company has a commercial legal entity and has not been able to submit the consignment notes showing that the goods allegedly left to the client on consignment to the file during the lawsuit. Although the plaintiff company is a legal entity, it has the opportunity to show its commercial books as evidence, but until this time, they have only been able to submit the lists prepared unilaterally by themselves to the file. The documents in question have no legal validity.
2- In addition, the letter submitted to the file by the plaintiff is a photocopy and the original document could not be submitted despite the strict deadline. There is not even a signature under the photocopy document submitted by the plaintiff. A photocopy document is a document that can be easily organised. Our client cannot be under suspicion due to a document that has no signature and has never been given to the plaintiff by the client. Since this contradictory situation is incompatible with the facts, showing this situation as if it actually happened with a method found later is a completely unfair and imaginary fiction prepared in bad faith.
CONCLUSION and REQUEST:
As presented and explained in detail above; we declare that we do not accept the plaintiff’s allegations; We declare that we do not consent to the expert examination on photocopied documents, since no original documents can be presented in the court vault and the plaintiff does not comply with the strict deadline. We hereby request that the lawsuit filed by the plaintiff, which is unfair and without legal basis, be dismissed, that the plaintiff be sentenced to malice compensation not less than 20%, and that the litigation costs and attorney’s fees be left on the plaintiff.
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