……. TO THE HONOURABLE JUDGE
REQUEST FOR AN INJUNCTION
CLAIMANT :…….
DEFENDANT :…….
DEFENDANT :…….
SUBJECT : Negative Determination
VALUE :…….
EXPLANATIONS :1-Our client runs a boutique. He agreed to buy women’s and men’s trousers from the Defendant. Who has a clothing workshop, in accordance with the contract dated ……. between them.
2-My client gave the defendant the promissory notes. For the goods purchased on credit according to the contract on the date of the contract. The dates and amounts of the promissory notes were also written in this contract.
3-After the contract date, there was a big fire in the site. Where the defendant’s workshop was located, and the defendant’s shop. Was heavily damaged. The defendant told our client that he would bring. The goods from third parties as soon as possible, if necessary. He said that the promissory notes. Were also burnt in the fire and that they could prepare new ones. When he delivered the goods. Our client trusted the defendant and accepted. However, although a reasonable time has passed. The goods belonging to our client have not arrived.
4-The defendant also took a precautionary attachment on the promissory notes. That he had received from our client and which were due. As well as on the promissory notes that were not yet due, ……. Enforcement Directorate’s ……. The defendant made a follow-up with the file numbered .
5-Our client has no debt to the defendant. Our client is a serious merchant who keeps all kinds of official books and invoice records regularly. The contract is clear. The promissory notes were given against the goods to be delivered by the defendant. Promissory notes given. By the defendant for the goods ordered from the defendant were recorded in the foreign exchange book. The goods have not been delivered to our client.
6-Therefore, it is necessary to open this case.
7-We request the determination that our client has no debt to the defendant and the cancellation of the promissory. Notes executed by the defendant.
EVIDENCE : Contract, Execution File and all kinds of legal evidence.
RESPONSE TIME : 10 days
CONCLUSION OF THE REQUEST : For the reasons explained; with the acceptance of our lawsuit. To determine that our client is not indebted to the defendant. To cancel the promissory notes given pursuant to the contract, to determine. That the defendant does not have any receivables ……. Enforcement Directorate ……. No. , the defendant to be penalised with 40% compensation. The costs and judicial expenses to be charged to the other party. And the counterparty’s attorney fee to be decided on our behalf as a lawyer in accordance. With the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
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