25 May Action For Spesific Performance
…….JUDGE OF THE COURT OF LAW
PLAINTIFF :
ADDRESS :
Acting :
ADDRESS :
DEFENDANT :
Address :
Subject: the same performance (if not, refund of the price) consists of our request.
INSTRUCTIONS
1 -) Our client, in order to make parquet floor flooring, defendants … TL. he bought m2 parquet … for a price.
2 -) in the article of the sale contract signed between our client and the defendant on/…/…, it is decided that the price of the parquet subject to the contract will be transferred by our client to the account numbered in the bank branch of the defendant on / … / … date, and in the article, the parquet subject to the contract will be delivered by the defendant (Appendix-1)
3 -) Our client has fulfilled the action imposed on him by the contract. The bank note on this issue is attached. (Annex-2) however, the defendant has not fulfilled his obligation either on the date set out in the contract or on the date set out in the notification number of the notary public’s office …/ …/ … sent to him by our client. (Appendix-3)
4 -) Our client has been in a difficult situation due to his inability to take delivery of the parquets he will use during the renovations he has been making in his house. For this reason, the same delivery of parquets, if the same performance is not possible, the price of paid parquet … TL.in order for the defendant to be taken and paid to our client, it is required that you apply to your court.
Legal reasons: 6098 P. K. m. 123, 124, 125, 126.
LEGAL EVIDENCE :
1 -) … / … / … dated sales contract,
2 -) Bank Statements
3 -) … Notary Public’s notice no. / … / … date and … day.
4 -) Expert Examination
RESULT AND PROMPT
For the reasons explained above, our client …/ …/ … the same delivery of the parquet purchased by the sales contract dated, if the same performance is not possible, the price of the parquet paid … TL.we respectfully request that the defendant be paid to our client by taking it from the defendant, that the costs of the trial and the power of Attorney be charged to the other party, and that the decision be made on behalf of our client. …/ …/ …
ECLAIR :
1 -) … / … / … dated sales contract,
2 -) Bank Statements
3 -) … Notary Public’s notice no. / … / … date and … day.
4 -) One Certified Power Of Attorney Sample.
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