TO THE … COURT
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
address :
SUBJECT : Collection of commission receivables, deprived profits and compensation for equalization caused by Unfair Termination of the Agency Agreement includes our request is our petition.
INSTRUCTIONS :
1- dec Between our client and the defendant …/…/…. an agency agreement has been signed that loads debts to both parties on its date. (ANNEX-1) Our client has started his insurance agency activity with this agreement. The term of the contract has been decided as … a year, and it has been decided that the contract will be extended for … a year if the insurance company has not been advised that the contract will not be extended until the day before the end of the period.
2-) The expiry date of the contract is …/…/…. our client in this direction because there is no warning before the deadline was extended for any year of the contract term, although the …/…/…. without informing our client on the date, our client’s online connection was disconnected and his activities were blocked, and then … our client was informed that the contract was terminated with a warning dated /… /… issued at his notary’s Office (ANNEX-2).
3-) Our client will receive a commission from the defendant. In addition, due to unfair termination, our client’s commercial reputation has been damaged and he has been deprived of profit. If the contract is terminated unfairly, our client is required to pay an appropriate equalization (portfolio) compensation to our client by the insurance company for the customer environment left by the agent to the insurance company, since it is fair that the insurance company will receive a commission, the interest on the deprived profit and equalization compensation, as well as the defendant’s request to decide on the collection of this case was required to open the business.
LEGAL REASONS : 6102 P. K. m. 121, 122
LEGAL EVIDENCE: …/…/… dated agency agreement …/…/…dated notice, business books, expert review, oath
Results and PROMPT : for the reasons we described above …TL Commission receivables is calculated by expert witnesses arises to be increased if more fully and precisely determined to be increased, allowing it to be possible at the time) … and deprive abdominal musculature arises if TL is calculated to be increased by more expert witnesses (fully and precisely determined to be increased, allowing it to be possible at the time) …TL offset compensation rates (may vary according to the demand), with collection from the defendant, we respectfully request on behalf of our client that the judgment costs and the power of attorney be decided to be charged to the opposite party. …/…/…
ANNEXES: 1-) …/…/… dated agency agreement
2-) …/…/… dated warning,
3-) An example of a certified power of attorney
Plaintiff’s Attorney
