… TO THE MAGISTRATE OF THE COURT

PLAINTIFF :

ADDRESS :

Acting :

ADDRESS :

DEFENDANT :

Address :

SUBJECT: … – TL. it includes our request to prevent unfair competition with material, …-TL moral compensation and to decide on the return of the property we have the right to own.

INSTRUCTIONS

1 -) for years produced by our client and consumed with acclaim all over the world … brand … in order to be marketed throughout Turkey, a number of willing private and/or legal persons, including the defendant party, have been awarded contracts in practice known as “franchising contract” (Annex 1). The registration certificate dated and numbered (Annex 2), which states that the right of ownership of the mentioned trademark belongs to our client, is presented in the annex of our petition.

2 -) as can be seen from the examination of the text of the contract which we have signed with the defendant party and presented in the annex to our petition, our client, who is in the position of the founder and long-term protector of the system as a feature of the franchising institution and is called “franchisor ” in practice, has the, he established it at the address of the defendant, which he reported as his workplace and which he operated continuously throughout the year, and delivered it to the defendant in case of business. The delivery is recorded in full and complete minutes dated …/…/… with the signature of the respondent (Annex 3).

3 -) the duration of the mentioned contract is stipulated as … years. Upon the expiration of this period, no extension has been granted, based on the right granted to our client by clause Pearl of the contract. Thus, in accordance with the article … of the section of the same contract under the name of “general conditions”, the obligation to return the inventory items which were delivered to the defendant at the beginning of the work was born in the same and free of charge. However, the defendant party, by making up some unsubstantiated pretexts, avoided the return of the goods in question and kept seven of them.

4 -) The defendant party, not satisfied with this, continued to produce and sell the products on the menu given to him by our client under the same name and features, contrary to the … TH article in the section of the contract under the name of “General Conditions”. With respect to the aforementioned circumstances, it includes our notice to the defendant … with the Notary Public’s …/…/… dated and daily numbered notice (Annex 4 ) and the determination of the activity carried out in spite of this notice … of the Court of Magistrates ‘ Court …/… D.The minutes (Annex 5) relating to the determination made through the work numbered file have been submitted to the examinations of your court in the annex to our petition.

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

The fixtures established at the workplace and delivered to the defendant in a working condition are devices specially designed and manufactured from the highest quality material for the best performance of the intended activity. In this way, if the defendant wishes to continue his activities independently, he shall be free from a burdensome investment expense.

In addition, our client, who has a well-deserved reputation in the food industry, owes this reputation to the diligence and diligence he has shown in his work. However, even during the period in which the contract in question is in force, the defendant party has had some problems with the quality of the products, continued to use the signs, names, logos and brands belonging to our client during the production period which it continues to carry out unfairly after the term of the contract has expired and not only engaged in unfair competition,

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

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

LEGAL EVIDENCE :

1-franchising agreement dated … / … / … ,

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

3 – … / … / … ,

4 – … Notary Public … / … / … dated

5 – … daily notice number,

6 – … Of The Court Of Magistrates … / … D.Job number file

7-exploration and expert examination,

8-witness statements

RESULT AND PROMPT

For the reasons we have tried to explain above, … TL material, … TL moral compensation to be taken from the defendant to be given to US, property rights to our client’s trademark to prevent unfair competition, our client’s property property returned to US, court costs and attorney fees to the defendant to be installed to the decision, respectfully and by proxy. …/…/…

ACTING PLAINTIFF