22 Sep AN EXAMPLE OF A PETITION OF ACTION OF DEBT
TO THE CIVIL COURT
THE PLAINTIFF : ……………………….
ATTORNEY: At. ….
THE DEFENDANT : ……………………….
THE VALUE OF THE CASE : …….. – TL
SUBJECT:……… TL monthly % ……… it is our request that the collection be decided together with the interest.
OUR EXPLANATIONS
1.Client .the defendant…………. he has signed a contract dated …/…/… to receive it. However, it was received from the defendant……..delivery of…/…./……. the client has suffered damages due to non-compliance.
2.The decency of the said agreement between the parties …. according to the item no.; payments will be made as follows……. As can be seen from the attached current account table, the client has made his payments regularly on the october dates.
3. however, the defendant party has not fulfilled its responsibilities under this agreement, and although we have been warned by the notice of its notary public on the date of / … / … in order to fulfill the actions subject to the contract, no concrete steps have been taken by the defendant to perform the actions.
4. In light of the considerations described above, it was necessary to open this case.
EVIDENCE :
1. The dec. … / … / … agreement concluded between the parties,
2. Invoices and documents for all repairs made up to the date of the case
3. Current account statement,
4. … Notice of the notary …/…/… dated … previous date,
5. Expert review,
6. Business books and records,
7.All kinds of other evidence.
CONCLUSION AND REQUEST : Due to the failure to deliver the ……that my client received from the defendant, provided that we reserve the right to request and sue for the specified reasons and for the excess………………… TL We sincerely supply and demand by proxy that the monthly interest to be calculated from the date of the case, as well as the collection from the defendant, the costs of the trial and the attorney’s fee be charged to the defendant, be decided upon by proxy.
Plaintiff Attorney
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