TO THE COURT OF FIRST INSTANCE
(Injunction Requested.)
Plaintiff:
ATTORNEY’S ATTORNEY:
DEFENDANT:
SUBJECT OF THE CASE: It consists of the request for the return of the ……….. brand car with the plate number ………, which was sold under the conditions of the bag.
EVENTS: 1- My client, ……….., has accumulated money for years and bought a car as a result of this savings.
2- Since my client’s wife is a kidney patient, she goes to the hospital regularly every month and is connected to the dialysis machine. For this, he pays ……..(………) TL every month. My client, who was dismissed from his job due to the economic crisis, decided to sell his car because he could not find the money he needed to give to the hospital this month.
3- The defendant, who knows about this situation of my client ………. He tells my client that he can buy his car, but the car will only cost ….. (…….) TL. My client, who needed money urgently, did not have the opportunity to do market research, so he sold his car to the defendant for ……… TL (……..) and transferred it from the notary public.
4- My client, who received the money, immediately took his wife to the hospital and had him connected to the dialysis machine. Later, my client asked how much a car of the same model would be sold for. The owner of a car of the same model said that he would sell the car for ……… TL and even though they gave ……….. TL, he did not sell it. Thereupon, my client realized that he had been deceived.
5- My client explained this situation to the defendant, but the defendant said that there was nothing he could do now that the transfer was made from the notary public.
6- For these reasons, it has become necessary to file a lawsuit regarding the return of the car sold under the conditions of loss by applying to your Court within one year from the transfer from the notary public.
LEGAL REASONS :
EVIDENCE: Witness, expert and all kinds of legal evidence when necessary.
CONCLUSION AND CLAIM: With the acceptance of our case, with the acceptance of our case, it was decided to put an annotation on waiver as a precautionary measure in the traffic registry in order to prevent the transfer of the subject car to third parties, to cancel the license issued in the name of the defendant and to issue the license in the name of my client, and to load the trial expenses to the defendant, with our respect, by proxy, we request. ../../..
Plaintiff’s Attorney
Hunting………………….
(SIGNATURE)
ADDITIONAL:
