COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Prevention of Name Violation.
FACTS : 1- My client is a very famous singer recognised in Turkey. Having given many concerts abroad, my client’s fame has also travelled abroad.
2- The defendant, who wants to benefit from my client’s fame, states that he will soon release his new cassette under my client’s name. He has placed advertisements in the newspapers.
3- The defendant’s announcement that he will release a cassette tape using my client’s name constitutes a usurpation of my client’s name. If the adverts in the newspapers cannot be prevented, my client will suffer great damages.
LEGAL GROUNDS :
EVIDENCE : Population record, witness statement, newspaper advertisements and all kinds of evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, I request that our lawsuit be accepted and the defendant be prevented from placing advertisements under the name of “……………..” and that the works related to the new cassette he intends to release be seized and prevented with a precautionary injunction decision until the end of the trial, that the sales of the new cassette, if it has released the new cassette to the market, be stopped and the advertisements not be published, and that the defendant be charged with the costs of the trial and the attorney’s fee.
I hereby submit my request. Sincerely yours,
Plaintiff’s Counsel
Attorney………………….
(SIGNATURE)
ANNEX:
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