…….YOUR HONOR
PRECAUTIONS ARE REQUESTED
…….
PLAINTIFF :…….
ACTING :…….
RESPONDENT :…….
CASE : Receivables case
SUBJECT : our client ……. it is a request for collection of the receivable together with the legal interest.
EXPLANATIONS:1-Our client , the defendant……… in its history, it has sold its passenger car. According to the written agreement made between the defendant ……. remaining paid in advance ……. and for them, they have agreed on a term payment.If one of the installments is not paid, the other one will be considered overdue. In addition, the defendant has also agreed to our client to receive a precautionary and precautionary lien unsecured in case of non-payment as required by the contract.
2-Our client delivered the vehicle to the defendant on the promised day and also gave it for sale from a notary public. He also handed over all kinds of receipts to the defendant stating that the vehicle does not owe taxes and stamps.
3-The defendant ……… our client must provide ……. he did not pay the installment amount and did not answer our client’s numerous calls.
4-Our client heard that the defendant took the car to the auto sunday to sell it, and later found out that the defendant had deceived several other people in this way and did not pay their money.
5-Our client must pay the defendant according to the contract…….. it requests that the amount of the receivable be paid together with the interest to be processed from the date of installment. Because, according to the contract, the first installment has not been paid, the second one is considered to be overdue. In addition, in order for our client not to become a victim later, he also wants measures to be taken to prevent the transfer of the license plate of the vehicle he transferred to the defendant to third parties-without asking for collateral from my client under the contract.
LEGAL REASONS : UK.the relevant provisions of
EVIDENCE: Dated sales contract, witness and other legal evidence.
RESPONSE TIME: 10 days.
THE RESULT OF THE REQUEST :For the reasons described, our client is from the defendant…….. the amount transferred to the defendant for collection from the defendant together with the legal interest that will be calculated from the date of installment of the receivable, in order for our client not to become a victim later .. .. …. we demand that measures be taken to prevent the transfer of license plate number of the vehicle to third parties-without asking for guarantee from my client under the contract, to transfer the costs of the trial to the defendant, and to decide on the counterparty proxy fee on our behalf in accordance with paragraph 164/last amended by Law 4667 of the Law No. 1136 on the Attorney’s Law No. 1136.
ACTING PLAINTIFF
