ALANYA 1ST ENFORCEMENT LAW COURT
FILE NO : ………
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : It consists of submitting our responses to the lawsuit.
EXPLANATIONS :
We are the attorneys of ……………. in accordance with the attached power of attorney.
Against the plaintiff ………….. ‘Antalya General Enforcement Office ………………. Enforcement proceedings were initiated through the file numbered …………., the vehicle with the licence plate number ………….. belonging to the debtor…………… was seized and taken under custody, Alanya Enforcement Directorate …………. Appraisal was made through the file numbered instruction.
According to the appraisal report dated …………….. prepared by the Mechanical Engineer ………………… for the determination of the value of the vehicle. The engine and transmission control could not be performed since the vehicle did not have a key and the doors were locked. Otherwise the second hand market value of the vehicle was determined as 200.000,00 TL.
It is clear that the plaintiff debtor will not suffer any loss of rights since the seized property will be subject to sale by auction as a result of enforcement proceedings. The plaintiff has no legal interest in objecting to the valuation.
However, we request that the debtor’s objections be evaluated and a final decision be made as soon as possible by conducting discovery. And expert examination in line with the decision of the Honourable Court in the direction of discovery / expert examination. 09.12.2021
LEGAL GROUNDS : EBL and other relevant legislation.
EVIDENCE : Discovery, expert, witness statements and any other evidence.
CONCLUSION AND REQUEST : For the reasons we have presented and explained above;
We submit our answers to the lawsuit and the appraisal should be made by an expert again,
Since we did not cause the lawsuit to be filed, we respectfully request that the costs of the proceedings and the attorney’s fee be charged to the other party.
………………….Representatives
Atty…………………..