Petition For Annulment Of Fraudulent Dispositions
TO THE … CIVIL COURT
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT : Request for Sale and Cancellation of Title Deed.
CASE VALUE :
A P P L A C T I O N S
1-) The defendant … owes my client … TL. in accordance with the sales contract they made. Despite the warnings made by my client, the debt was not paid.
2-) Thereupon, an enforcement proceeding was filed against the defendant. Although the debtor’s … brand vehicle was seized as a result of the enforcement proceedings, the debt was not fully repaid and the client was given a ‘Certificate of Insolvency’ by the Enforcement Directorate.
3-) We have learned that the defendant sold his vehicle to … for … TL. while the enforcement proceedings were continuing. Therefore, it has become compulsory to file this lawsuit.
LEGAL GROUNDS : Art. 277, 279 of 2004 S. Code and related legislation.
LEGAL EVIDENCES : Execution file, notary deed, witness statements and other evidence.
CONCLUSION AND REQUEST
For the reasons explained and explained above, we respectfully request on behalf of our client that the sale be canceled, and that the costs of the proceedings and the attorney’s fee be charged to the other party. …/…/…
Counsel for the Plaintiff
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