-SAMPLE PETITION-
ANKARA ( ) EXECUTIVE DIRECTORATE
THE USE OF THE RIGHT TO IMPRISONMENT
THE REQUESTER
PROSECUTOR :
ADDRESS
ATTORNEY:
ADDRESS
DEFENDANT :
ADDRESS
SUBJECT OF REQUEST: It is about our request to use the right of imprisonment on the defendant’s movable property in order to guarantee that the client will receive a lease.
INSTRUCTIONS
Defendant C….. E…., in the residence whose ownership belongs to the plaintiff client../../…. he/she is living as a tenant in accordance with the lease agreement dated from the beginning (October-1). According to the contract concluded between the parties, the monthly rental price of the rented housing is 000 Dec00TL and will be paid on the first day of each month.
Despite the contract concluded between the parties, the defendant did not pay the last … monthly rent until the Deci-sion date, Ankara ….Executive Directorate ‘s 2021/….. A payment order (October-2) was sent to the tenant who owes the payment order via the principal receivable of a total of TL 000.00, which is equivalent to unpaid rent with the numbered main file../../….it has been communicated in its history.
Respondent debtor to the follow-up request …/…./…. although he has appealed in his history, this appeal is unfair and malicious. When the client confronted the defendant tenant, it was also seen that the defendant declared that he would not pay the debt and tried to escalate things with the discussions that took place. It is necessary to guarantee the defendant’s debt to the client. TBK 36 “lessor a lease of immovable, which are in operation a year and six monthly rental price assurance of committed, including the laying of in loans, loans, or to be used on the right has moved to prison.” In accordance with it, the client wants to secure his receivables.
As a result, in order to guarantee that the client will receive, your Directorate requests that the movable property belonging to the defendant tenant located in the housing subject to the request be identified and the plaintiff client’s right to temporary imprisonment be allowed to be used on these goods.
LEGAL REASONS : TBK, IIK, HMK, Av. Law and other relevant legislation
EVIDENCE : Ankara ….Executive Directorate ‘s 2021/….. E. Subpoenaed file No., ../../…. The Lease Agreement with the Initial Date, the Expert report (If Deemed Necessary), Other all kinds of delail
CONCLUSION AND REQUEST: For all the reasons described above and re’ you will be considered by your Directorate,
1-Acceptance of our request and determination of movable property belonging to the respondent tenant,
2- We offer and request that the determination costs, trial costs and the power of attorney be decided to be left on the counterparty. 07/10/2021
Requesting the Exercise of the Right to Imprisonment
A…. B…… Acting
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