…….YOUR HONOR

INJUNCTION IS REQUIRED

…….

Plaintiff:…….

ACTING :…….

RESPONDENT :…….

Lawsuit: receivables lawsuit

Subject: our client……. it is a request for collection along with legal interest.

Explanations: 1-Our client, the defendant…….. in its history, it has sold passenger cars. According to a written agreement between them, the defendant ……. remaining paid in advance ……. for, they have agreed on term payment.If one of the installments is not paid, the other will be considered overdue. In addition, the defendant has also consented to our client’s unsecured injunction and injunction in case of non-payment.

2-Our client delivered the vehicle to the defendant on the day he promised and gave it to the notary. He also handed over to the defendant all kinds of receipts that the vehicle did not owe taxes and stamps.

3-defendant……. our client must provide ……. he did not pay the installment amount and did not return numerous calls from our client.

4-Our client heard that the defendant brought the car to the auto market to sell it, and then learned that the defendant had deceived several other people in this way and did not pay their money.

5-Our client must pay the defendant in accordance with the contract……. it asks that its receivables be paid together with the interest to be processed from the date of installment. Because the first installment is not paid according to the contract, the second one is considered to be due. In addition, in terms of our client not being a victim later, the license plate of the vehicle he transferred to the defendant is also requested to be taken into consideration in terms of preventing the transfer to third parties-without requiring collateral from my client in accordance with the contract.

LEGAL REASONS: UK.related provisions

Evidence: dated sales contract, witness and other legal evidence.

Response time: 10 days.

Claim result :for the reasons described, our client is from the defendant……. along with the legal interest that will be calculated from the installment dates that you will receive, the collection from the defendant is transferred to the defendant, so that our client is not a victim later .. .. …. in order to prevent the transfer of the license plate number of the vehicle to third parties-without requiring collateral from my client in accordance with the contract-we demand that the injunction be taken, that the costs of the trial be charged to the defendant, that the counterparty’s attorney fee be decided on our behalf as a lawyer in accordance with the last paragraph 164/amended by law 4667 of the law 1136.

ACTING PLAINTIFF

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