TO THE … CIVIL COURT
PLAINTIFF:
TC IDENTIFICATION NUMBER :
ADDRESS:
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS:
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
CASE VALUE : …….. TL
(In cases related to the subject of the case and property rights)
SUBJECT : … Consists of our Request for a Negative Detection based on 89/3 in the Follow-up File of the Enforcement Directorate /.
INSTRUCTIONS :
1-) The defendant is the follow-up creditor … Ltd. Şti. client … A.Sh.’what, the out-of-court stalking debtor… A.Sh.allegedly, the client was born from a contract with the company … TL. he sent an 89/1 lien notice on the date /… /… because he would receive it, and after no objection was raised during the period, the second notice was notified on the date /…//.(APPENDIX 1)
2-) The client’s follow-up debtor is … A.Sh.’he has no debt as mentioned. The client company’s follow-up debtor is out of the case… A.Sh. 4000 cans of various canned goods were found defective in the sales contract (APPENDIX 2) that he signed with … /… /… on the date, after which the said contract was terminated by the client company … A.A compensation lawsuit has been filed against him … with the main file of the Court. (APPENDIX 3) This compensation case, which has been filed, has been concluded on the date /…/… and the damages arising from the defective property are out of the case … A.Sh. it has been decided that it will be covered by.
3-) 89/3 of the Enforcement and Bankruptcy Code of 2004 for these reasons, which we have explained. the client’s follow-up debtor within the period specified in article … A.Sh.’there has been an obligation to open this case to determine what he does not owe.
LEGAL REASONS : 2004 P. K. m. 89.
LEGAL EVIDENCE : Execution follow-up file, signed between the parties dec …………… the dated contract, the Court’s decision on the merits, the expert review, the witness statements (if requested, their names and addresses will be notified to the court.).
CONCLUSION AND REQUEST: For the reasons we explained above, my client’s non-lawsuit follow-up debtor … A.Sh.’we respectfully request on behalf of our client that it be determined what he does not owe, that the defendant has committed unfair and malicious enforcement proceedings, that the case value is not lower than 20%; that he be sentenced to bad faith compensation, that the trial expenses and the attorney’s fee be charged to the opposite party. …/…/…
Attachments : 1……The Executive Directorate …./…. Tracking file number
…./….. dated sale agreement
3……. The Court…./…. E. case file no.
4.The names and addresses of the witnesses and the topics they will testify to
shows witness list,
5.An example of a certified power of attorney.
Plaintiff’s Attorney
