Petition For The Return Of The Goods Due To Defective Goods And Request For Payment Of The Price
… CONSUMER COURT
DEFENDANT : (TR ID NO: )
AGENT :
DEFENDANT :
SUBJECT : It is requested to return the defective goods and to pay the price.
EXPLANATIONS :
1-) The client purchased … brand, … model and … color vehicle from the defendant on …/…/… date. (ANNEX 1) As of the date of purchase, the value of the carpet is … -TL.
2-) While selling the vehicle, the seller agreed with the client that he had the vehicle checked by the …expertize company 2 days ago and that there were no accidents, paint and changing parts. As a result of this agreement, the client paid …-,000-TL to the seller. …/…/…. dated …/…/…. at the … Notary … The sale was realized with the vehicle sales contract with the journal number … (ANNEX-1 : …/…/…. dated … report of the expert firm)
3-) 2 weeks after this sale …/…/…., the client, who was suspicious of the subject vehicle, went to … auto expertise company to get a re-expertise report and had his vehicle checked. During these checks, it was determined that the vehicle had been involved in an accident before, was heavily hit from the front side, and that the airbags and seat belt safety systems were defective (ANNEX 2- …/…/… dated … Auto Expertiz company. report)
4-) The client then wanted to go to the expert firm where the first report was given, but since there was no such company, he could not reach the company and understood that the report received was fake. (We reserve our right to complain about the incident.) It has become necessary to file this lawsuit in order to return the … brand…model…color…plate vehicle that the client has purchased to the seller.
LEGAL GROUNDS : 6502 S. K. art. 8, 66, 73, 6100 S. K. art. 6, 266
LEGAL EVIDENCE : Contract of sale dated …/…/…, invoice dated …/…/…, photograph, letter of application to the defendant dated …/…/…, reply letter dated …/…/…, expert
CONCLUSION AND REQUEST : For the reasons explained above and to be investigated ex officio;
Our lawsuit is accepted,
to return the notary sale price of the lost vehicle ….00-TL to the client,
the costs of the proceedings and attorney’s fees to be charged to the defendant,
We request a decision to be made.
Plaintiff Representative
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