…….TO THE PRESIDENCY
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT: Our request for the delivery of …… in kind or the refund of the installments paid.
EXPLANATIONS: 1-Our client purchased a Deep Freezer Refrigerator from the “Buy Today, Pay in 12 Months” campaign launched by the defendant.
2-My client paid the down payment of ……. in accordance with the terms of the contract and took delivery of the refrigerator. Fifteen days after the refrigerator arrived, upon complaints that it was not cooling, the seller, the defendant, immediately took the old refrigerator from my client to replace it with a new one. Our client, who delivered the refrigerator to the seller with a written record, has not yet received the new refrigerator.
3-Meanwhile, our client has paid two more installments, each amounting to ……. Our client, who verbally warned the seller who did not deliver the refrigerator, has not achieved any results. We request that the defendant be ordered to return the refrigerator or the installments paid by our client, together with interest.
LEGAL GROUNDS: Consumer Protection Law
EVIDENCE: Contract receipts
RESPONSE PERIOD: 10 days.
RESULT OF THE CLAIM: For the reasons stated, the ……. purchased by our client should be delivered to our client as is, or if this is not possible, the total amount of ……. , along with the legal interest accrued since the payment dates, be paid to our client, the litigation costs be borne by the defendant, and the opposing party’s attorney’s fees be awarded to us as attorneys, in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY