AN EXAMPLE OF A APPEAL PETITION ABOUT REQUEST FOR A STAY OF EXECUTION

TO THE RELEVANT LEGAL DEPARTMENT OF ANTALYA REGIONAL COURT OF JUSTICE

To Be Presented

TO THE ANTALYA … EMPLOYMENT COURT JUDICATURE

 

DEPORTATION IS REQUESTED FOR EXECUTION.

 

…./…. Base

…./…. Decision

DEFENDANT : ….

ATTORNEY: ….

 

PLAINTIFF : ….

ATTTORNEY: ….

 

SUBJECT : The decision made by the court of first instance with the acceptance of our appeal must be lifted until the case is dismissed and the execution of the decision made by the Ankara … Employment Court until the appeal review is completed, (if enforcement proceedings have been initiated, Ankara … Enforcement Directorate …/… E. it consists of a request to decide on the release of enforcement proceedings No. 1).

 

INSTRUCTIONS :

…..

 

CONCLUSION-I REQUEST: For the reasons explained above and for the reasons that will be respected by your court;

Until our request for deportation execution is accepted and the appeal review is completed, Ankara … will suspend the execution of the decision made by the Employment Tribunal, (if enforcement proceedings have been initiated, Ankara … Enforcement Directorate …/… E. release of enforcement proceedings No. 1)

Ankara … Labour Court …/… E. …/… K. As a result of the decision No. 1 to be abolished and re-tried, a provision for the rejection of the case should be established,

We offer and request that a decision be made on the transfer of the trial expenses and the proxy fee to the counterparty. …/…/…

Defendant’s Attorney