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Sample Petition For Jurisdiction Objection To The Executive Court

Eviction Of The Workplace Due To Necessity Supreme Court Decision

TO BAKIRKÖY ( ) EXECUTIVE CIVIL COURT JUDGE

 

EXECUTIVE DIRECTORATE and FILE NO:

 

Bakırköy…. Enforcement Directorate 2015/….. E.

 

PLAINTIFF/DEBTOR:………………………………. (TR ID Number: …)

 

DEPUTY:

 

Address:

 

DEFENDANT/CREDITOR:

 

Address:

 

SUBJECT OF REQUEST: It is our objection to authority.

 

REMARKS

 

The payment order regarding the enforcement proceedings for bills of exchange initiated against the client from the Bakırköy ( ) Enforcement Directorate’s file numbered 2015/….. E. was notified to the client on …./……/2015, and we object to the authority within the legal period (5 days).

 

My client, ………………. He resides at the address of K.Çekmece/İstanbul, and as can be seen when the enforcement file is examined, the address specified by the creditor in the follow-up request and to which my client was notified is the address of K.Çekmece.

 

The place of drawing of the check subject to follow-up is Istanbul, and the authorized enforcement offices regarding this check are Istanbul or K.Çekmece Enforcement Directorates.

 

Although the defendant / creditor has the right to choose to initiate proceedings in Istanbul or K.Çekmece enforcement offices, the prosecution was initiated in Bakırköy Enforcement Directorates, which are unauthorized.

 

It has become necessary to request a decision to accept our authority objection, provided that our right to object to the debt, signature, interest and all other accessories of the debt is reserved.

 

LEGAL REASONS: EBL, TTK, HMK other legal legislation

 

CONCLUSION OF DEMAND: For the reasons presented and explained above,

 

With the acceptance of our authority objection, Bakırköy …. Lack of authority of the Enforcement Directorate,

 

Cancellation of the proceedings initiated by the unauthorized enforcement directorate,

 

It has been determined that K.Çekmece Enforcement Directorates are authorized for the receivable subject to follow-up,

 

I respectfully request, as attorney, that it be decided that the litigation expenses and fees be charged to the defendant party…./…../

 

 

 

Plaintiff’s Attorney

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