… … JUDGESHIP OF THE ENFORCEMENT LAW COURT
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
AMOUNT OF CLAIM : …TL
SUBJECT : It consists of the request for final removal of the objection and continuation of the proceeding.
EXPLANATIONS :
1- In the enforcement proceeding we initiated against the debtor with the enforcement file numbered …/… of the … Enforcement Directorate, the debt and authorization objection was made and then the proceeding was stopped.
2- The claim that the enforcement office that conducted the enforcement proceeding is unauthorized is contrary to the law. The enforcement proceeding was filed at the enforcement office in the debtor’s place of residence.
3- The debtor’s objection to the debt is also not appropriate. The bill of exchange subject to enforcement proceedings was issued between the debtor and my client, the creditor, pursuant to the vehicle sales contract and has not been paid yet. The debtor objected to the authorization and the debt, did not object to his signature on the bill and acknowledged his signature.
4- For the reasons explained above, it has become necessary to apply to your authority with the request to remove the objection of the debtor who cannot present a valid payment document in terms of the law of enforcement.
LEGAL GROUNDS : Article 68 of 2004 S. Law and related legislation.
LEGAL EVIDENCE : …/…E numbered follow-up file of the enforcement office, …./…./…./…. dated contract, original and photocopy of the promissory note and other evidence.
CONCLUSION AND REQUEST : We respectfully request on behalf of our client that the objection made for the reasons we have explained above be definitively removed in accordance with the Execution and Bankruptcy Law, that 20% execution denial compensation be awarded against the debtor, and that the judicial expenses and attorney fees be charged to the debtor. …/…/…
Counsel for the Plaintiff
ATTY.
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