Petition For Compensation Regarding The Protection Of Name
TO THE HONORABLE COURT
PLAINTIFF:
ATTORNEY:
DEFENDANT:
SUBJECT: Action for damages regarding the protection of a name.
EXPLANATIONS :1-Our client is a well-known and beloved merchant in his neighborhood. By nature, our client is not very involved with his surroundings and is known for his calm personality.
2-Annoyed by our client’s indifference, his neighbor named his dog after our client and had this name written on its collar in order to attract attention and provoke our client.
3-The defendant walks his dog in the gardens among crowds of people sitting and chatting at the busiest times of the neighborhood and frequently calls it using our client’s name.
4-Our client is hurt and feels humiliated by the defendant’s behavior.
LEGAL GROUNDS: MK.m.25, BK.m.49 and 41.
EVIDENCE: Witness, Population Registry, Witness Statements, and All Types of Evidence.
RESPONSE PERIOD: 10 days.
CONCLUSION: For the reasons stated, the defendant shall cease this action that is hurting our client, and the defendant shall be ordered to pay our client ……. , that the defendant be ordered to pay compensation, that the costs of the proceedings be borne by the defendant, and that 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