TO THE CONSUMER COURT

prosecutor :

TC IDENTIFICATION NUMBER :

address :

attorney :

(Legal representatives of the parties, if any)

address :

(Legal representatives of the parties, if any)

DEFENDANT :

address :

SUBJECT : It includes our request for the collection of TL paid in advance from the defendant with the cancellation of the timeshare agreement /…/… made between the parties………………… dec.

INSTRUCTIONS :

1-) Between our client and the defendant …/…/… on Dec., ……….. A contract of sale of a timeshare property with a price of TL has been drawn up. (APPENDIX – 1)

2- dec Over the sales contract concluded between the parties …. although the month has passed, the land registry of the property has not yet been transferred to our client. However, according to the contract concluded, the delivery date …./…/… and our client cannot use the timeshare property because it has not been transferred on the land registry.

3-) Our client claims that the defendant has exercised his right to withdraw from the contract with a notice dated /… /… due to the violation of the contract, the cancellation of the contract and that he has paid in advance ….. Although he requested the refund of the TL, the notice sent by the defendant was not answered and no payment was made. (APPENDIX – 2)

4-) Due to the defendant’s violation of the timeshare agreement concluded, with the cancellation of the contract, paid in advance ….. He has been obliged to apply to your court for the refund of the TL.

LEGAL REASONS : 634 P. K. m. 57, 58, 59, 60, 61, 62, 63, 64, 65.

LEGAL EVIDENCE : 1-)…./…/… timeshare sale agreement dated

2-) …/…/… dated notice

3-) Expert Review.

CONCLUSION AND CLAIM: Due to the defendant’s violation of the timeshare agreement for the reasons described above, with the cancellation of the contract, paid in advance ….. We respectfully request on behalf of our client that it be decided that TL will be collected from the defendants, trial expenses and power of attorney fees will be charged to the other party along with the legal interest that will be processed from the date of the case. …/ …/ …

Plaintiff’s Attorney

Addition:

1-) …./…/… timeshare sale agreement dated

2-) …/…/… dated notice

3-) Expert Review.

4-) An example of a certified power of attorney