Request For Removal Of Content Pursuant To Law No. 5651
… TO THE PEACE CRIMINAL COURT
PETITIONER: TC No:
ADDRESS:
ATTORNEY:
ADDRESS:
OPPOSING PARTY:
ADDRESS:
SUBJECT: This petition contains our request for the removal of the content at the address www….. and the publication of a response text.
OUR EXPLANATIONS
1-) On the website www……, under the headline …, published on …/ …/ …, false information began to be published stating that our client has assets worth … TL and that he made this fortune from his … business.
2-) Our client is the owner of the company …, which has been operating in the … sector for … years. There have been no criminal proceedings regarding the investments made and projects completed by his company in its field of activity. Moreover, our client’s asset declaration for the year … clearly shows, with supporting documents, that he does not possess assets in the amount mentioned in the publication, and this fact is self-evident.
3-) Regarding the content we request to be removed from publication, our application to the content provider with our petition dated …/ …/ … has been unsuccessful, and the publication continues. It has become necessary to apply to your court with this petition for the removal of the relevant content from publication.
LEGAL GROUNDS: Law No. 5651, Article 9.
LEGAL EVIDENCE:
1-Trade registry gazette belonging to the company named … owned by our client
2-Our client’s property declaration petition dated …/…/…
3-The application petition submitted by our client on …/…/…
4-The news text published on www….. on …/../…
CONCLUSION AND REQUEST: For the reasons explained above, we request, on behalf of our client, that the news article published on www…… on …/ …/ … under the title … be removed from publication, that the response text prepared by us be published at the same address for one week, that the litigation costs and attorney’s fees be borne by the opposing party, and that a decision be rendered. …/ …/ …
ATTACHMENTS:
Attorney for the Petitioner