DECLARATION PETITION – CLARIFICATION OF THE SUBJECT OF THE WITNESS’S TESTIMONY (PRIMARY COMMERCIAL)
ISTANBUL …. TO THE HONOURABLE PRESIDENCY OF THE COURT OF FIRST INSTANCE
FILE NO: 2013/…….. Basis
THE PLAINTIFF
DEFENDANT: Av
DEFENDANT
SUBJECT: This is our petition containing our declarations on which subject to testify and our statements against the document submitted by the defendant.
DISCLOSURES
The receipts submitted by the defendant at the hearing dated ………………… are not related to the payment as the defendant claims:
I- The defendant declared that he paid his debt to the client at the hearing dated …………………… and submitted two receipts showing that this payment was made. This claim is not appropriate, when the receipts are examined, it is obvious that there are payments made in relation to the loan debt of the vehicle. Moreover, it is clearly and clearly written on the receipt that the money deposited was collected as a pledge removal fee, which was paid directly from the client’s own account to the bank where the defendant had a loan debt, provided that it was a sales advance. This proves our allegations by showing that the defendant’s claims were not in the right from the very beginning.
II-The event will be revealed more clearly and clearly with the hearing of the witnesses whose names have been notified by us. Namely
The client wanted to buy the bus, in which the defendant has a half share, from the other partner …………………….. A.Ş., and when the sale transactions started, due to the pledge on the vehicle, the pledge price was paid by the client as an advance payment for the sale and the pledge on the vehicle was removed. However, the sale transaction was abandoned with the placement of liens arising from other debts on the vehicle, but the money paid by the debtor to the client as an advance on the sale was not returned.
The client even started transactions regarding the operation of the minibus with the idea that he would buy the vehicle.
By hearing the witnesses whose names have been reported, it will become clear that there is a purchase and sale relationship between the debtor and the client company official, that the money paid by the client to the bank was deposited as an advance for the sale of the vehicle and that the pledge on the vehicle was removed with this amount paid by the client.
We request that the necessary action be taken and that our witnesses be heard, and we submit it to your appreciation and tensipip.
Plaintiff Attorney
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