ANKARA (…) SENTRY FIRST INSTANCE LAW COURT
Executive Directorate : Ankara 1.Executive Directorate File No. 2021/123451
REQUESTING THE CANCELLATION OF THE APPEAL
PROSECUTOR :
ADDRESS :…………
ATTORNEY :
ADDRESS :
PHONE :
DEFENDANT :
ATTORNEY :
ADDRESS :………………………………………
CASE VALUE :…………….. TL
T.SUBJECT : Made by the defendant (the debtor of the Enforcement Directorate File) …/…./ the cancellation of the appeal dated 2021 consists of our request to decide on the continuation of the follow-up and to award executive denial compensation not less than 20% of the receivable.
Ankara 1 by the Defendant (The Debtor of the Execution File).2021/12345 E of the Executive Directorate. be notified within the scope of the numbered file an appeal against the order of payment within the period decided on by the Executive Directorate to stop tracking, and to petition the debtor has been notified by the decision; 1-year period, I’ve been the substitution of this case.
INSTRUCTIONS
The defendant’s objection to what the Enforcement Directorate has done is unfair and malicious. As follows, on October 01, 2020, the product I submitted to the defendant with the attached documents belonging to me was delivered, and the invoice was sent to him. The octoberiqués and documents related to the dispatch procedures and the receipt of the invoice are attached. The content of the invoice was not challenged by the defendant, but the payment process was not made by the defendant within the time limit.
Despite all my warnings, the defendant has not paid his debt due to the fact that he is about Ankara 1.2021/12345 E of the Executive Directorate. it has been followed up within the scope of its numbered file and the payment order has been unfairly and maliciously challenged by the defendant.
In addition, the amount to be pursued is well known to the defendant and is also a liquid receivable.
LEGAL REASONS: Enforcement Bankruptcy Law, Turkish Code of Obligations, Turkish Commercial Code, etc. relevant legislation
EVIDENCE: Subpoena of the Enforcement Directorate file, dated invoice, dispatch documents, mail correspondence, witness, expert report, oath, discovery, etc. all delail.
CONCLUSION AND CLAIM : For all the reasons described above and which will be considered by your court you’re:
1-ACCEPTANCE OF our Case, CANCELLATION OF the Appeal and CONTINUATION OF THE PROCEEDINGS
2-Not less than 20% of the actual receivable, the defendant will be awarded COMPENSATION FOR DENIAL OF EXECUTION against
3-I request that all kinds of trial expenses, fees and power of attorney fees be left to the defendant party and that a decision be made.
PLAINTIFF (CREDITOR)/DEPUTY