… TO THE PRESIDENT
PLAINTIFF:
ATTORNEY:
DEFENDANT:
SUBJECT: Our request for the delivery of … or the refund of the installments paid.
EXPLANATIONS
1- Our client purchased a Deep Freezer Refrigerator from the “Buy Today, Pay in 12 Months” campaign launched by the defendant. My client paid the deposit in accordance with the terms of the contract and took delivery of the Refrigerator. Ten days after our client received the refrigerator, the seller took the old refrigerator from our defendant client and replaced it with a new one due to complaints that the refrigerator was not cooling.
The new deep freezer refrigerator has not yet been delivered to our client, and our client has handed over the receipt and the refrigerator to the seller. Meanwhile, our client paid three more installments, each amounting to … TL. Our client warned the seller, who failed to deliver the refrigerator as promised, but to no avail. We request that the defendant be ordered to pay our client the price of the refrigerator or the installments paid by our client with interest.
LEGAL GROUNDS: Consumer Protection Law
EVIDENCE: Contract and receipts
RESPONSE PERIOD: 10-day response period
RESULT OF THE CLAIM: For the reasons explained above, we request that the goods purchased by our client be delivered to our client, or, if such delivery is not possible, that the total amount paid by our client to the defendant seller in installments and as a down payment be paid to our client, along with legal interest accruing from the date of payment, all litigation costs to be borne by the defendant, and the opposing party’s attorney’s fees to be determined by us in accordance with the last paragraph of Article 164 of Law No. 1136, as amended by Law No. 4667. …/…/…
Plaintiff’s Attorney