תביעה נגד חברת תעופה זרה, החזר כספי של כרטיסי טיסה

March 14^th, 2022 WITHOUT PREJUDICE

To: _________________

Customer Relations

United Kingdom

Re: FULL REFUND DEMAND

BOOKING REFERENCE: W9JZJD

CAUTION PEIOR TO LEGAL ACTION

On behalf of Mr. _____________ (hereinafter: "My Client"), I hereby approach you as follows:

1. On February 14^th 2020, my client ordered from you three (3) flight tickets to the USA for the departure date on August 5^th 2020 and paid directly to your company the full cost of the tickets in the amount of $ 4,757.13 in one payment using a Visa card ending in digits # 4321 and in addition $552 (for seats) using a Visa card ending in digits # 1234.

Attached is a copy of the order confirmation, marked as Appendix A.

2. The purpose of the flight was to attend a family member's wedding.
3. However, close to the above date, my client received a notification from you that the flights had been canceled.
4. My client demanded a full refund from you, but you chose to ignore it and in response you sent him vouchers for new tickets without receiving his approval and consent.

Attached and marked as Appendix B.

5. My client has tried to call you many times to protest this and even sent detailed emails requesting a refund but you have not returned it to this day.
6. My client put his trust in you, paid the full cost of the tickets and waited patiently for your obligations regarding the handling of the refund to be fulfilled but so far nothing was done in your side.
7. Despite my client's demands to receive what he deserves in a peaceful manner, you try to avoid it, illegally and in complete violation of the law and case law.
8. my client will persist to demand all his rights until he receives the last penny he deserves including compensation for the insult, anguish and waste of time, loses and expenses.
9. Your company has violated the basic terms of the agreement, the law and its own obligations and the service agreement that you publish online.
10. My client was very tolerant and waited for you to handle the refund in good faith, but your company's conduct in this regard is very far from it.
11. Therefore, my client will give you one last notice regarding the payment you owe him before filing a claim in court.
12. There is no doubt that the violations and omissions described above have resulted in and continue to result a various types of damage to my client.
13. This conduct is intended to deprive my client from the money he deserves.
14. 15. Also and in according to the Israeli Aviation Services Law (compensation and assistance due to cancellation of a flight or change in its conditions) (the new Corona virus – Temporary Order – Amendment), 5720-2020, you had to ensure that the funds were returned to my client long ago .

16. Below is a list of the debt you owe my client:

16.1. The ticket cost + the seats cost: $ 4,757 + $552 = $5,309.

16.2. Compensation for the anguish, contempt and waste of time: $ 500.

16.3. Reimbursement of legal expenses in the amount of $ 750.

In total your debt to my client is $ 6,559.

17. You are required to provide my firm with your response within a maximum of 14 days.
18. In the absence of a response or a fair, final settlement of the parties' relationship by March 30^th 2022, My Client has instructed me to realize its rights in whatever manner, with anything that entails, including legal actions and complaints to govermental offices.
19. That mentioned and un-mentioned herein will not prejudice My Client's claims against you.

Sincerely

Dror Harel, Adv.