Petition For Change Of Company Name During The Litigation
… COURT OF FIRST INSTANCE
FILE NO:
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT: Pursuant to the interim decision, correction of the title of the defendant company and submission of our statements
EXPLANATIONS
1- Since the defendant … A.Ş. changed its title after the lawsuit was filed, we are correcting the title of the defendant company as … A.Ş.
2- Due to the damage, our Company has suffered a total financial loss of … -Turkish Lira. As stated in the discovery documents, after deducting …-TL material, …-Turkish Lira labor and vehicle expenses, …-Turkish Lira collected material expenses, the total amount of …-Turkish Lira total material and labor amount and 18% … VAT was added to the total amount of …-Turkish Lira and the total damage incurred was calculated as …-Turkish Lira.
To our total … Turkish Lira receivable,
From the date of damage … until the date of partial payment …, ….% advance interest = …Turkish Lira was charged, and …Turkish Lira paid on … was deducted from the interest in accordance with Article 84 of the Code of Obligations, and …Turkish Lira interest receivable remained.
A lawsuit has been filed for the collection of … Turkish Lira principal receivable and … Turkish Lira interest, totaling … TL … for the collection of the principal receivable with interest to be accrued as of the date of partial payment … from the date of payment.
3- As per the law, the VAT rate to be applied is 18% and we objected to the calculation made at a different rate in the determination report.
4- It is clear that the defendant’s objections regarding jurisdiction and hostility are not a proper objection, and the decision of the Court of Cassation … Civil Chamber …/… E and …/… K. numbered decision, which we submitted to the Court file, reveals the groundlessness of the objections
CONCLUSION AND REQUEST:
For the reasons I have stated above, I respectfully request that the title of the defendant company be corrected and our lawsuit be approved. …/…/…
Counsel for the Plaintiff
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