TO THE COURT OF FIRST INSTANCE
Plaintiff:
TURKISH IDENTITY 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 : … It consists of our Request for Negative Determination based on 89/3 in the Follow-up File of the Enforcement Directorate numbered …/….
DESCRIPTIONS :
1-) To the defendant follow-up creditor … to the client … For his receivables, he sent a seizure notice on …/…/… on 89/1, and upon failure to object in due time, a second notice was served on …/…/… (Annex 1).
2-) The client does not have any debts to the debtor … as mentioned. The 3 pickup trucks subject to the contract of sale (Annex 2) signed by the client on the date of …/…/… with the follow-up debtor … were found to be defective, and the contract in question was subsequently terminated by the client, and a compensation case was filed against … with the file numbered …/… of the Court of …. (Annex 3) This lawsuit for compensation was concluded on …/…/… and it was decided that the loss arising from the defective goods would be covered by the non-litigation ….
3-) For these reasons we have explained, Article 89/3 of the Execution and Bankruptcy Law No. 2004. In order to determine that the client is not indebted to the debtor …
LEGAL REASONS: 2004 N. K. m. 89.
LEGAL EVIDENCE:
CONCLUSION AND CLAIM: For the reasons we explained above, it is determined that my client does not owe the debtor of out-of-court proceedings… On behalf of our client, we respectfully request that he be sentenced to bad faith compensation, and that the litigation expenses and attorney’s fees be charged to the other party. …/…/…
ATTACHMENTS:
Plaintiff’s Attorney
