Petition For Objection To Extension Of Defense
…… COURT
PLAINTIFF :
PROVISIONAL :
ADDRESS :
DEFENDANT :
ADDRESS :
SUBJECT : Our Statements About the Lawsuit.
EXPLANATIONS
1-) We filed a lawsuit against the defendant, our client…, due to the initiation of enforcement proceedings with a mortgage document of …TL. despite the payment of …TL. that we made to him, and we requested the deferment of execution due to the performance of the debt.
2-) However, the defendant stated that this debt was not paid at the hearing dated …/…/…/…, although the defendant accepted the payment of …TL. at the hearing dated …/…/….
3-) It is an indisputable provision that the extension or amendment of the defense after the case is entered into the merits is subject to the permission of the other party. We also do not consent to the other party’s extension of the defense that ‘… TL… has not been paid’. As a matter of fact, we hereby submit the payment receipts for the …TL. we have paid with this petition.
LEGAL GROUNDS : Article 202, 33 of 1086 S. Code and the relevant legislation.
LEGAL EVIDENCES : Payment receipts, witness statements and other evidence.
CONCLUSION AND REQUEST
For the reasons we have explained above, taking into account that we do not consent to the defendant’s extension of the defense that the debt has not been paid at the hearing dated …/…/…, we request and demand that the execution be deferred until the end of the case in accordance with the provisions of Article 33 of the Execution Law due to the payment of …TL. made to the defendant, which is the creditor, and that the judicial expenses be charged to the defendant.
Plaintiff Attorney