…….HONORABLE JUDGE
A REQUEST FOR PRELIMINARY INJUNCTION IS MADE
…….
PLAINTIFF: …….
CAPACITY: …….
DEFENDANT: …….
CASE: Debt Collection Case
SUBJECT: This is a request for the collection of the debt owed by our client ……. along with legal interest.
EXPLANATIONS: 1-Our client sold his passenger car to the defendant ……… in the past. According to the written agreement between the defendant ……… and our client, they agreed on an installment payment plan for the down payment. In the event that one installment is not paid, the other installment shall also be deemed overdue. Additionally, the defendant agreed to grant our client the right to an unsecured provisional lien in the event of non-payment as required by the contract.
2-
Our client delivered the vehicle to the defendant on the agreed-upon date and also provided a notarized sales authorization. Furthermore, our client handed over all receipts confirming that the vehicle had no outstanding tax or stamp duty liabilities to the defendant.
3-The defendant is required to provide our client with the necessary information regarding the payment; however, the defendant failed to pay the installment amount and did not respond to our client’s numerous calls.
4-Our client heard that the defendant had taken the car to a car dealership to sell it and later learned that the defendant had defrauded several other people in this manner and failed to pay them.
5-Our client is obligated to make payment to the defendant pursuant to the contract… He demands payment of the outstanding amount, including interest accruing from the installment due date. Since the first installment was not paid, the second installment is also considered overdue. Additionally, to prevent our client from suffering further harm, he requests that measures be taken to prevent the vehicle’s license plate—which was transferred to the defendant—from being transferred to third parties without requiring collateral from our client, as stipulated by the contract.
LEGAL GROUNDS:
In accordance with relevant provisions in the United Kingdom
EVIDENCE: Dated sales contract, witness testimony, and other legal evidence.
Response period: 10 days.
REQUEST:
For the reasons stated above, our client is requesting that the amount transferred to the defendant be recovered from the defendant, along with statutory interest calculated from the due date of the debt, to prevent our client from suffering further harm. … … Additionally, in accordance with the contract, we request that the transfer of the vehicle’s license plate number to third parties be prevented without requiring security from our client, that litigation costs be borne by the defendant, and that, pursuant to Article 4667, Paragraph 164 of the Lawyers’ Act No. 1136, , we request that the necessary measures be taken to determine the opposing party’s attorney’s fees on our behalf.
ATTORNEY FOR THE PLAINTIFF