Petition for Cancellation of a Check and Imposition of a Payment Prohibition

TO THE DUTY PRIMARY COMMERCIAL COURT

ISTANBUL

PLAINTIFF: [Name and Surname] – (Turkish Republic Identity Number: …) – [Address]

REPRESENTATIVE: [Attorney's Name and Surname] – [Address]

DEFENDANT: [Name and Surname] – [Address]

SUBJECT OF THE CASE: Request for a preliminary injunction against a check cancellation and payment prohibition order.

EXPLANATIONS:

1. A check issued in the name of [Person X], with serial number [Check Serial No.], dated …/…/… and for the amount of … TL, issued by … Bank … Branch, has been lost or stolen. Considering the possibility that the check was taken, a complaint was filed with [Police Department Name] on …/…/… with incident number … (Appendix 1)
2. The check in question, for the amount of … TL, was issued in the name of my client, person X, and has been lost. If the check falls into the hands of a third party, my client will inevitably incur debt and suffer losses. This situation would result in my client being unjustly liable for debt and third parties being unjustly enriched.
3. Therefore, in order to prevent my client's suffering from worsening and to prevent third parties from unjustly enriching themselves, it is necessary to issue a preliminary injunction.

EVIDENCE:

1. A photocopy of the said check (Appendix 2: Photocopy of the Check)
2. Police report (Appendix 1: Copy of Police Report)
3. Complaint form and related documents regarding the lost check (Appendix 3: Complaint Form and Related Documents)
4. All correspondence of the client company regarding the check (Appendix 4: Correspondence and Related Documents)

LEGAL GROUNDS: The Enforcement and Bankruptcy Law and related legislation.

CONCLUSION AND REQUEST: For the reasons explained above, I respectfully request and demand that a preliminary injunction be issued to prevent my client's harm and to prevent unjust enrichment of third parties, and that the court costs and attorney's fees be borne by the defendant. …/…/…