-SAMPLE PETITION-
ANKARA SENTRY ( ) IS AN EXECUTIVE JUDGE
WITHDRAWAL OF EXECUTION
THE REQUESTER
PLAINTIFF (DEBTOR)
ADDRESS :………
ATTORNEY :
ADDRESS :
PHONE :
DEFENDANT(CREDITOR):
ADDRESS :…………………
SUBJECT OF REQUEST : Ankara ….Executive Directorate ‘s 2021/….. It is our request that a decision be made to cancel the enforcement proceedings conducted with the main numbered file.
INSTRUCTIONS
By creditor plaintiff client A….. B….. against Ankara ….Executive Directorate ‘s 2021/….. Continuous follow-up has been initiated through the main numbered file (ANNEX-1) and the executive order has been issued to us../../…. it has been communicated in history.
HR 33. we submit our requests for the withdrawal of enforcement in accordance with the article as follows within the legal period. That is to say;
HR 39. According to the article “Ilama müstenit”, the follow-up is subject to a statute of limitations with the passage of ten years after the last treatment. it is said that “. Decriminalization is between the plaintiff client and the defendant creditor../../…. In history, ….. The promissory note in the amount of TL (ANNEX-2) has expired between the start date of the decissory note and the follow-up date, which is accepted in accordance with the IIK.
As a result, this pursuit, which was initiated in violation of the procedure and the law, is malicious and unfair. There is no such debt belonging to the client. For all these reasons, it has been our responsibility to request the release of this unfair enforcement proceedings initiated against the client.
LEGAL REASONS : IIK (33-39 and all other articles), HMK, Av. Law and other relevant legislation
EVIDENCE : Ankara ….Executive Directorate ‘s 2021/….. E. Subpoenaed file No., ../../….dated promissory note, Expert report (If Deemed Necessary), Other all kinds of delail
CONCLUSION AND CLAIM: For all the reasons described above and which will be considered by your court you’re,
1-Plaintiff client A….. B….. IIK m of the enforcement proceedings initiated against him.to be Released Back in accordance with 33,
2-We offer and request that it be decided that the costs of the trial and the power of attorney be left on the counterparty. 14/09/2021
Requesting the Withdrawal of the Execution