TO THE … HONORABLE JUDICATURE
THE MEASURE IS IN DEMAND
…….
PLAINTIFF :…….
ATTORNEY:…….
RESPONDENT :…….
CASE : Receivables
SUBJECT : Our client’s ……. it is a request for collection together with the legal interest of the receivable.
REMARKS:1-Our client , the defendant ……… in its history, it has sold passenger cars. According to the written agreement they made between them, the defendant ……Dec. remaining paid in advance ……. and for them they have agreed on a term payment.If one of the installments is not paid, the other one will also be deemed overdue. In addition, the defendant, in accordance with the contract, also agreed that our client would receive precautionary and precautionary liens without collateral in the event of non-payment.
2-Our client delivered the car to the defendant on the day he promised, and also gave him a notarized sale. He also handed over to the defendant all kinds of receipts that the vehicle did not owe taxes and stamps.
3-The defendant ……. our client must provide ……. he did not pay the installment amount and did not answer our client’s numerous calls.
4-Our client heard that the defendant took the car to the auto sunday to sell it, and then found out 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 requests that the amount of the receivable be paid together with the interest that will be processed from the installment date. Because the first installment is not paid according to the contract, the second one is also considered overdue. In addition, in order for our client not to become a victim later, he wants a measure to be placed on the license plate of the vehicle that he transferred to the defendant in order to prevent its transfer to third parties – without asking my client for collateral under the contract.
LEGAL REASONS : BK.relevant provisions of the
EVIDENCE : Dated contract of sale, witness and other legal evidence.
RESPONSE TIME : It is 10 days.
As A RESULT OF THE REQUEST : For the reasons described, our client is from the defendant ……. together with the legal interest that will be calculated from the installment dates of the amount that you will receive, which you will transfer from the defendant to the defendant for collection, so that our client does not subsequently become a victim.. .. …. in terms of the Prevention of the transfer vehicle plate number plate No. to third parties-contract my client collateral from unintentionally rotated, the court of costs and expenses to the defendant to yukletilm, No. 1136 different 4667 of the attorneyship Law, Article No. 164/the other party in accordance with the last paragraph attorneys ‘ fees as an attorney on behalf of that, we will request the decision to be given to govern.
PLAINTIFF’S ATTORNEY
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