A REQUEST FOR THE FINAL REMOVAL OF THE APPEAL AND THE CONTINUATION OF THE FOLLOW-UP

ADMINISTRATIVE LAW COURT

 

THE CREDITOR
WHO WANTS THE APPEAL TO BE
DEFINITIVELY REMOVED ​:

 

attorney :

 

DEBT :

 

attorney :

 

AMOUNT OF RECEIVABLES: …TL

 

SUBJECT : It consists of a request for the final removal of the appeal and the continuation of the pursuit.

 

INSTRUCTIONS :

 

1- The enforcement proceedings that we initiated against the debtor … with the follow-up file of the Enforcement Directorate … /… have been objected to and the pursuit has been stopped. The debtor objected to the authority of the Enforcement Directorate and the debt.

 

2- The claim that the enforcement Agency conducting the follow-up is unauthorized is not in place, because at the time the follow-up was opened, the debtor … resides within the city limits of the Enforcement Directorate’s jurisdiction … in the city. The fact that the borrower has moved out of the city after the follow-up does not affect the authority of the Enforcement Directorate.

 

3- The borrower’s objection to the debt is also not in place. The following deed has been arranged between the dector and my client’s creditor in accordance with the book sale agreement and has not yet been paid. The debtor objected to the authority and debt, did not object to the signature on the promissory note, and confessed his signature.

 

4- For the reasons we have explained above, the borrower who cannot provide a valid payment document in terms of follow-up law has been required to contact your authority with a request to have his objection removed.

 

LEGAL REASONS : 2004 P. K. m. 68 and related legislation.

 

LEGAL EVIDENCE :… The follow-up File of the enforcement agency …/…E, …./…./…. dated contract, original and photocopy of the deed and other evidence.

 

CONCLUSION AND REQUEST: We respectfully request on behalf of our client that the appeal filed for the reasons described above be definitively removed in accordance with the Enforcement and Bankruptcy Code, that a 20% enforcement denial compensation be ruled against the debtor, and that the trial expenses and the attorney’s fee be charged to the debtor be decided. …/…/…

 

 

Plaintiff’s Attorney (Creditor)