نمونه شکواییه چک پرداخت نشدنی به دلیل خارج کردن وجه از حساب

با عرض سلام و تحیت احتراما به استحضار عالی می‌رساند:

1-مشتکی عنه به موجب بدهی خود، ……….فقره چک به شماره……….در تاریخ……….. عهده بانک…………..در شهرستان………… شماره …….. به مبلغ………….ریال در وجه بنده صادر کردند.
2-لازم است یادآوری شود که نامبرده با نشان دادن صورت حساب خود و داشتن وجه، اقدام به صدور چک مزبور کرد.
3-اینجانب در تاریخ مقرر با مراجعه به بانک و خالی بودن حساب مشتکی عنه گواهی عدم پرداخت به شماره …………….. مورخ………………….. دریافت کردم و متوجه شدم که ایشان سریعا بعد از صدور چک به وسیله …………………. اقدام به خالی کردن حساب خود کرده است.
4-همچنین بنده با توجه به درخواست مشتکی عنه، چندین بار به ایشان مهلت دادم. با اتمام مهلت و مراجعات مكرر نزد ایشان مطمئن شدم که نامبرده قصد پرداخت بدهی خود را ندارد.
5-لذا با توجه به ادله اینجانب که شامل: 1- اصل چک و گواهی عدم پرداخت به شماره ……….. تاریخ ………….. 2- ………….. 3- ………………… و همچنین به استناد ماده 3 قانون صدور چک اصلاحات 1382، رسیدگی و تعقیب و مجازات متهم از دادگاه محترم مورد استدعا است.
6-به خسارات وارده به بنده که مبلغ…………… ریال است، بدوا تقاضای صدور و اجرای فوری تامین خواسته را دارم.

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انتشار توسط 8 تم
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