Sample Appeal Petition Requesting Stay of Execution Proceedings
ANTALYA REGIONAL COURT OF JUSTICE
For Presentation
ANTALYA … LABOR COURT JUDGE
WITH A REQUEST FOR ENFORCEMENT.
…./…. E.
…./…. K.
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : With the acceptance of our appeal application, it consists of the request for the decision to be made until the decision given by the first instance court is abolished and the case is dismissed and the execution of the decision given by the Ankara … Labor Court is postponed until the appeal examination is concluded , (if enforcement proceedings have been initiated, Ankara … Enforcement Directorate …/… E. numbered enforcement proceedings are postponed).
EXPLANATIONS :
…..
CONCLUSION-DEMAND : For the reasons presented and explained above and for the reasons to be taken into consideration by your court ex officio;
To defer the execution of the decision given by the Ankara … Labor Court until the appellate review is finalized by accepting our request for deferral of execution, (if enforcement proceedings have been initiated, Ankara … Enforcement Directorate …/… E. numbered enforcement proceedings to be deferred)
Ankara … Labor Court …/… E. …/… K. To abolish the decision numbered …/… E. …/… K. and to establish a judgment for the rejection of the lawsuit as a result of the retrial,
We request and demand that the judicial expenses and attorney’s fee be imposed on the other party. …/…/…
Counsel for the Respondent
…………………………………
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