TO THE … HONORABLE JUDICATURE
…….
PLAINTIFF :…….
ATTORNEY:…….
RESPONDENT :…….
SUBJECT: Provided that we reserve the right to request and file a claim for an excess …………………- The monthly % that you will receive in TL …… it is a request to decide on its collection together with interest.
REMARKS : 1-My client company is engaged in the production of ready-mixed concrete. If the defendant, ……….. he has undertaken the expansion construction of his factory. Therefore, to get the ready-made concrete that he needs from our company, see the attached …….October…………… he made the dated contract. In accordance with this agreement, our company has received ready-mixed concrete on various dates.
2-According to paragraph 3 of the attached contract; payments will be made with 30/60/90-day term checks. Likewise, article 5 of the contract.according to the article; 12% monthly interest will be calculated on receivables transferred to the current account because they have not been paid. 9 of the Convention. according to the article, Kocaeli Courts are authorized in disputes.
3-As can be understood from the attached, current, statement of accounts, the respondent party is overdue in payments, and the sum of these delays is …….. and then ……. When VAT is added, the counterparty’s debt under the contract …….it holds.
EVIDENCE : Contract, current account statement, company records, expert review, other legal evidence.
RESPONSE TIME: It is 10 Days
AS A RESULT OF THE REQUEST: For the reasons mentioned above and with the registration of our right to claim and sue for excess …….. our receivables will be calculated monthly from the date of the case…….we request that it be decided to collect the interest from the defendant together with the defendant, to charge the trial costs to the defendant, and to judge the opposing party’s attorney fee on our behalf as a Lawyer in accordance with paragraph 164 / last amended by Law No. 4667 of the Lawyer’s Code No. 1136.
PLAINTIFF’S ATTORNEY
