Reply Petition Sample
……. TO THE HONORABLE JUDGE …….
FILE NO :…….
DEFENDANT RESPONDING TO THE REPLY:…….
ATTORNEY :…….
PLAINTIFF:…….
SUBJECT : Our Reply Petition.
EXPLANATIONS :
1- The lawsuit filed by the plaintiff is procedurally and substantively unfounded. We submit our answers to the lawsuit within 10 days from the notification of the petition.
As follows;
a) First of all, the lawsuit was not filed in the competent court. The lawsuit, which should have been filed in the court of our client’s domicile, was filed in the defendant’s own domicile court. Therefore, your court is not authorized.
b) The lawsuit is subject to a 1-year statute of limitations and was filed 3 years after the incident. For this reason, we also object to the case in terms of statute of limitations. The case should be dismissed in terms of statute of limitations.
c) In addition, our client was responsible for the incident together with ……….. We are aware that this person paid the plaintiff for the incident and received a certificate of release. Photocopies of the release documents are attached. It is against the law for the plaintiff to demand this money from our client again after all these years by forgetting what happened.
d)
e)
f)
2- As can be understood from the reasons explained above, we request that the lawsuit filed in violation of the law both in terms of substance and procedure be dismissed.
CONCLUSION OF THE REQUEST : For the reasons explained above, we request that our objections be accepted and the lawsuit be dismissed, the costs of the lawsuit be left on the plaintiff, and the attorney fee of the opposing party be awarded to us as an attorney in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
DEFENDANT’S ATTORNEY
…….
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