-SAMPLE Petition-
TO ANKARA ( ) EXECUTIVE DIRECTORATE
ALLEGED RATIO
FOUND
owed :
ADDRESS :………
ATTORNEY:
ADDRESS :
PHONE :O
SUBJECT OF THE REQUEST: It is the presentation of our claim for remuneration against the seizure made with the file numbered 2021/….. of the Ankara ….Executive Directorate.
DESCRIPTIONS
With the file numbered 2021/….. of Ankara ….. Enforcement Directorate (ANNEX-1), the decision to place a lien on the properties of client A….. B….., who is the debtor of the file, has become final; ../../…. While the foreclosure transaction is made on the date of the creditor D…. TO…. For the collection of his receivable, the property of the client A….. B….. has been seized.
Foreclosure proceedings, B… who are not aware of the enforcement proceedings. It happened while the property of C…. was temporarily in the possession of the client. During the foreclosure process, the third party B…, not the client, who is the file debtor of the goods in question. Although the client insistently stated that they belonged to C….
As mentioned above, ../../…. The client has nothing to do with the lien on the property. As can be seen from the invoices (Annex-2) we have submitted in the annex of this petition, the goods subject to seizure, B…. It belongs to C….
Therefore, pursuant to EBL 97, we request that the lien on the seized goods be lifted within the time limit, starting from the date of the lien, which is the date on which the client learned of the lien.
LEGAL REASONS: EVIDENCE: Subpoena of Ankara …. Enforcement Directorate’s file numbered 2021/….. E. Invoices regarding the goods subject to seizure, Expert report (if deemed necessary), All kinds of other claims
CONCLUSION AND REQUEST: For all the reasons explained above and to be taken into account ex officio by your Court, Ankara …Executive Directorate’s 2021/…. We respectfully submit and request the REMOVAL OF THE LIABILITY made with the file no. E. 09/09/2021
Debtor Claiming Remuneration
