09 Jul Petition For Personal Action
…….YOUR HONOR
…….
Plaintiff:…….
ACTING :…….
RESPONDENT :…….
Subject : we reserve the right to claim and sue for excess with registration …………………-monthly % you will receive in TL ……. it is a request that it be decided to collect along with interest.
Explanations: 1-My client is engaged in the production of Ready Mixed Concrete. If the defendant, ……….. he has undertaken the construction of the expansion of his factory. Therefore, the attached to get the ready-made concrete that it needs from our Company …….October…………… he made the contract dated. According to this contract, he received ready concrete from our company on various dates.
2-according to Paragraph 3 of the attached contract; payments will be made with checks with a 30/60/90-day term October. Also, 5 of the contract.according to the Article, 12% interest per month will be calculated for receivables transferred to the current account because they are not paid. 9 of the convention. according to the article,Kocaeli courts are authorized in disputes.
3-as can be seen from the attached,current,spreadsheet, the defendant party is delayed in payments,and the amount of these delays …….October…………… and then ……. When VAT is added, the counterparty’s contractual debt…….references
Evidence: contract, current account statement, company records,expert examination, other legal evidence.
Response time: 10 days
Claim result: for the reasons mentioned above and with the registration of our right to claim and sue for excess……. monthly, which will be calculated from the date of the case…….in accordance with the last paragraph 164/amended by Law No. 4667 of the Law No. 1136 of the law of Attorney, We demand that the counterparty’s attorney fee be decided on our behalf as a lawyer.
ACTING PLAINTIFF
…….
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