TO THE ISTANBUL … COURT OF FIRST INSTANCE

FILE NO: 2013/……….Base

IN A STATEMENT

DEFENDANT:

ATTORNEY:

PLAINTIFF:

ATTORNEY:

SUBJECT: Attorney of the plaintiff ………………………… it is our petition that contains our statements about the dated petition.

INSTRUCTIONS

The plaintiff, Mr. and presented to the court by US ………………… can be received on the date……………. acceptance of the petition dated by wire transfer is not possible. That is to say;

1- The plaintiff party claims in its petition that the client was maliciously given his products as a consignment for the purpose of sale in the name of not paying taxes. We do not accept the plaintiff’s allegations of tax evasion that he has made against his client. As dec explained in detail in our previous statements, there has never been any commercial relationship between the parties that should be recorded in the commercial book. Dec situation is also understood by the fact that the plaintiff cannot show any documents proving that there is a commercial relationship between the parties. The plaintiff company has a commercial legal entity and has not been able to file shipment documents indicating that there is a consignment of goods that were allegedly left to the client as a consignment for the duration of the case. Although the plaintiff company has a legal entity, they have the opportunity to show their commercial books as evidence, while up to this time they have only been able to submit lists prepared unilaterally by themselves to the file. The documents in question have no legal validity.

2- In addition, the article submitted to the file by the plaintiff is a copy, and the original document, despite the exact time, could not be submitted. There is even no signature under the photocopy document submitted by the plaintiff. A copy document is a document that can be easily edited. A document that is not signed and has never been given to the plaintiff by the client cannot be left under suspicion of our client because of it. Since this contradictory situation is incompatible with the facts, it is completely unfair and ill-intentioned to make this situation look like it actually happened by a method found later and consists of a fictitious imagination prepared in bad faith.

CONCLUSION and REQUEST: As presented and explained in detail above; the plaintiff declares that we do not accept his claims; We inform that we do not have the consent to conduct an expert examination on the photocopied document because no actual documents can be presented in the court case, the plaintiff does not comply with the exact deadline. We submit to your opinion and opinion that it is decided to dismiss the lawsuit filed by the plaintiff that is unfair and devoid of legal basis, to convict the plaintiff of compensation for malice not less than 20%, to leave the litigation costs and the attorney’s fee on the plaintiff’s side.

The Defendant Attorney