TO THE COURT OF THE VISIT …
(Injunction Requested)
Plaintiff: Name-Surname (TR Identity Number: …)
ATTORNEY: Atty. … (Insert information about your lawyer, if any)
DEFENDANT: Name-Surname (TC ID number and address, if you know)
SUBJECT OF CASE: Request for Negative Determination.
VALUE OF THE CASE: … TL
DESCRIPTIONS :
1- About the defendant on …/…/……. Enforcement proceedings numbered …/….. have been initiated by the Enforcement Directorate.
2- The plaintiff does not have any debts to the defendant due to … reasons. However, due to the enforcement proceedings initiated by the defendant, it was compulsory to file a negative clearance lawsuit.
LEGAL REASONS: Execution and Bankruptcy Law art. 72 and other relevant legislation.
LEGAL EVIDENCE: … Enforcement Office’s execution follow-up file, witness statements, bonds and other relevant evidence.
CONCLUSION AND CLAIM: For the reasons explained above, I request that it be determined that I do not owe the defendant, that the proceedings be stopped and interim injunction be decided, that the malicious defendant is sentenced to 20% compensation, that the costs of the trial be charged to the defendant.
