… … TO THE COURT JUDGE

PLAINTIFF :

TC IDENTIFICATION NUMBER :

ADDRESS :

Deputy :

(Legal representatives of the parties, if any)

ADDRESS :

(Legal representatives of the parties, if any)

DEFENDANT :

Address :

SUBJECT: …- TL. material, … – TL includes moral compensation and the Prevention of unfair competition and the decision to return the goods we have the right to property to us.

INSTRUCTIONS :

1-) produced by our client for many years in Turkey and all over the world, consumed with admiration for the brand … in order to be marketed, the respondent across the country, including some special eager and/or legal entities in the application with the “franchise agreement” (Appendix 1) from contracts of the type known as reviewed. Registration certificate (Annex 2), dated and … numbered, is presented in the annex to our petition.

2-) with the defendant and bagitlamis our petition that we are presented in the appendix as can be seen from an examination of the text of the agreement, the franchising authority as a feature of the system is the founder of, and long-term keeper at the position and the application located in the “franchisor, known as” our client “franchisore belong liabilities under the name of” chapter in edited in accordance with stipulated in the convention specified in the appendix of individual inventory item, he established it at the address that the defendant reported as a workplace and operated continuously throughout the year, and handed it over to the defendant in the case of work. It is recorded in the minutes (Annex 3) that the delivery was made in full and complete, dated and with the signature of the defendant.

3 -) the duration of the said contract is stipulated as … years. After the expiration of this period on the date, the extension of the period was not extended based on the right granted to our client by Article Pearl of the contract. Thus, in accordance with the article … contained in the section of the same contract, which is regulated under the name “General conditions”, the debt of returning the fixtures that were delivered to the defendant at the beginning of the work was born in kind and free of charge. However, the defendant, by making up a number of unsubstantiated excuses, avoided the return of the items in question and kept them in seven.

4-) the defendant, that been satisfied with the contract, “General Conditions” section is located under the name of … found in the edited article, contrary to previously listed in the menu to him by our client products under the same name and continued to produce and sell properties. In respect of these situations, it includes our notice to the defendant … in respect of the notary’s notice …/…/… dated and … numbered notice (Annex 4) and the determination of the activity carried out despite this notice … of the magistrate’s Court …/… D.The report on the determination made through the work file (Annex 5) has been submitted to the examinations of your court in the annex to our petition.

5 -) due to the attitude and behavior of the defendant, which is clearly contrary to the contract, both material and moral damage has been caused to our client. That is to say,

Fixtures installed at the workplace of the defendant and delivered to him in the working situation are devices specially designed and made of the highest quality material to ensure the best performance of the intended activity. In this way, if the defendant wishes to continue his activities independently, the defendant receives an unfair benefit by getting rid of a burdensome investment expense.

Besides all this, our client, who has a well-deserved reputation in the field of the food industry, owes this reputation to the care and diligence he has shown in his work. However, in case the convention is in force in the period in which we live some issues about the quality of the products even where the defendant’s wrongful conduct continuing after the contract expires during the production, our client belongs to signage, names, logos, and trademarks by continuing to use set out to eliminate an unfair competition, thoroughly reduced the quality of products, our client’s reputation in the eyes of the consumer caused significant damage.

6 -) for the reasons we have tried to explain above, it is necessary to open this case for material and moral compensation.

Legal reasons: 6102 P. K. m. 56, 556 S. KHK. m. 6

LEGAL EVIDENCE :

1 – … / … / … dated franchise agreement,

2 – … / … / … dated and … numbered trademark registration certificate,

3- …/…/… dated delivery minutes,

4 – … dated … / … / … of the Notary Public

5 – … notice of Duty,

6 – … Magistrate’s Court … / … D.File No. job

7 – discovery and expert examination,

8 – witness narratives

Conclusion and request : for the reasons we have tried to explain above, … TL material, … TL moral compensation is given to us by taking from the defendant, property rights are prevented from unfair competition due to the trademark of our client, the return of the asset belonging to our client to US, court costs and Attorney’s fees are charged to the defendant, I respectfully and by proxy. …/…/…

ECLAIR :

1 – … / … / … dated franchise agreement,

2 – … / … / … dated and … numbered trademark registration certificate,

3- …/…/… dated delivery minutes,

4 – … dated … / … / … of the Notary Public

5 – … notice of Duty,

6 – … Magistrate’s Court … / … File No. job

7 – discovery and expert examination,

8 – witness narratives

9-one sample of approved power of attorney.

Acting Plaintiff

Lawyer