Petition For Cancellation Of Savings
CIVIL COURT OF FIRST INSTANCE
(Provisional Attachment is Requested.)
Plaintiff: A ……… TC:
Address:
Representatives:
Address:
Defendants: B………TC:….Address
C ………TC:…Address
Case : Cancellation of sale and title deed (cancellation of disposal)
Explanations :
1. Defendant C ……… owes our client ……… ……….. TL. For this reason, we have initiated proceedings against him through the ……… Enforcement Directorate under file number ……… / ………
2. While the proceedings were ongoing and immediately before the proceedings, on ………, with the intention of concealing assets from the creditor, the defendant transferred the real estate located in ………, parcel number ………, to the other defendant B ……… and presented it as a sale.
3. The disposition made by the defendant debtor C ……… is subject to cancellation. There is a risk that the plaintiff may not be able to recover the debt. In this situation, it has become necessary to request the cancellation of the sale and the cancellation of the title deed on the defendant ………, as well as the restoration of the previous state in the title deed.
Legal Evidence: Enforcement case file, title deed, promissory notes, etc.
Legal Grounds: Enforcement and Bankruptcy Law Articles 277, 281, and relevant legislation
Conclusion and Request: We request that the court decide to cancel the defendant’s disposal of the real estate sold to the other defendant and restore the previous state, and that the real estate sold be provisionally seized in accordance with Article 281/2 of the Enforcement and Bankruptcy Law, and that the costs be borne by the defendants.
Plaintiff Creditor
Counsel