Petition Sample For Negative Determination Case After Execution Proceedings
TO THE … COURT ON DUTY
(Injunction Requested)
THE PLAINTIFF : Name-Surname (TR ID No: …)
ATTORNEY : Atty. … (Please write the information about your lawyer here, if any)
DEFENDANT : Name-Surname (Turkish ID number and address if known)
SUBJECT OF THE CASE : Negative Determination Request.
VALUE OF THE CASE : … TL
EXPLANATIONS :
1- On the date of …/…/…… …. Enforcement proceedings numbered …/….. were initiated by the Enforcement Directorate.
2- The plaintiff does not owe any debt to the defendant for … reasons. However, due to the enforcement proceedings initiated by the defendant, it has become obligatory to file a negative declaration case.
LEGAL GROUNDS : Article 72 of the BEC and other relevant legislation.
LEGAL EVIDENCE : … Enforcement Office enforcement proceedings file, witness statements, bond and other relevant evidence.
CONCLUSION AND REQUEST : For the reasons explained above, I request that it be determined that I do not owe any debt to the defendant, that an interim injunction be issued by stopping the proceedings, that the malicious defendant be sentenced to 20% compensation, and that the costs of the proceedings be imposed on the defendant. …/…/…
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