……….. COURT OF FIRST INSTANCE
APPLICANT: ……………………….
ATTORNEY: Attorney
DEFENDANT: ……………………….
VALUE OF THE CLAIM: …….. – TL
SUBJECT: We request a decision regarding the collection of the debt in the amount of…….. TL with monthly interest of ………%.
OUR EXPLANATIONS
The client signed a contract dated …/…/… with the defendant …… and undertook to take delivery. However, the defendant’s delivery of …….. on …/…./…… caused damage to the client due to the defendant’s failure to do so.
lass=”yoast-text-mark” />>According to Article no. of the contract between the parties in question, payments will be made as follows: As can be seen from the attached current account statement, the client has made payments regularly on the specified dates.
>However, the defendant has not fulfilled its obligations under this contract and, despite being warned by the notary on …/…/… with notification no. … regarding the fulfillment of the obligations under the contract, the defendant has not taken concrete steps to fulfill its obligations.
In light of the above, it has become necessary to file this lawsuit.
EVIDENCE:
The contract concluded between the parties on …/…/…,
Invoices and documents for all repairs made up to the date of the lawsuit.
>Current account summary,
Notarized certificate, dated …/…/…, date …, record no.<br />Expert examination,
Commercial books and records,
Any other evidence.
>CONCLUSION AND REQUEST: For the reasons stated above and due to the defendant’s failure to deliver the …… received by my client, we respectfully request that the amount owed be collected from the debtor, together with monthly interest of …… calculated from the date of the lawsuit, and that the defendant be charged for the lawsuit costs and attorney’s fees.
Plaintiff’s Attorney
Attorney