Petition For Debtor’s Claim Of Appropriation
……………. ( ) EXECUTION OFFICE
IN THE CLAIM FOR EMPLOYMENT
FOUND
DEBTOR :A….. B….. (T.C.:………..)
ADDRESS
AGENT :Lawyer …………………..
ADDRESS
SUBJECT OF REQUEST :
Ankara ….Execution Directorate’s file numbered 2021/….. It is the presentation of our claim of appropriation against the seizure made with the file numbered 2021/.
EXPLANATIONS
Ankara …. Execution Directorate’s file numbered 2021/….. With the file numbered 2021/….. (ANNEX-1), the decision to attach the property of the debtor client A….. B….., the decision to attach the property of the debtor of the file was finalised; while the attachment process was carried out on …/…/…., the creditor D…. E…. for the collection of its receivable, the ownership of which does not belong to the client A….. B….. for the collection of its receivable.
Seizure proceedings, B…. who was not aware of the execution proceedings C….’s goods were temporarily in the possession of the client. During the seizure process, it was realised that the goods in question did not belong to the client, the debtor of the file, but to the third party B…. C…. and that the client had nothing to do with the goods in question, the seizure of the goods could not be prevented.
As stated above, the client has nothing to do with the goods seized on …/…/….. As can be seen from the invoices (ANNEX-2) attached to this petition, the goods subject to seizure belong to B…. C…..
For this reason, in accordance with the BEC 97, we request that the seizure on the seized goods be removed within the period from the date of the seizure proceedings, which is the date the client learnt about the seizure.
LEGAL GROUNDS :
BEC (97 and all other articles), CCP, Law on Attorneys and other relevant legislation
EVIDENCE :
Ankara ….Execution Directorate’s 2021/….. E. numbered file subpoena, Invoices related to the goods subject to seizure, Expert report (If deemed necessary), Any other evidence
CONCLUSION AND REQUEST:
For all the reasons explained above and to be taken into consideration ex officio by your Court, we respectfully request that the seizure made by Ankara …Execution Directorate’s file numbered 2021/…. E. We respectfully request and demand that the seizure made with the file numbered 09/09/2021
Debtor Claiming Entitlement
A…. B……’s ATTORNEYS
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