TO THE COURT OF FIRST INSTANCE
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
CASE VALUE: …….. TL
(In cases related to the subject of the case and property rights)
SUBJECT : … It consists of our Request for Negative Determination based on 89/3 in the Follow-up File of the Enforcement Directorate numbered …/….
DESCRIPTIONS :
1-) Defendant follow-up creditor … Ltd. Sti. to the client … A.Ş., the debtor of non-litigation proceedings … TL. For his receivables, he sent a seizure notice on …/…/… on 89/1, and upon failure to object in due time, a second notice was served on …/…/… (Annex 1).
2-) The client does not have any debts to the debtor … A.Ş. as mentioned. The debtor of the client company is out of action … A.Ş. 4000 cans of miscellaneous cans, subject to the contract of sale (Annex 2) signed with the company on …/…/… were found to be defective, and the contract in question was subsequently terminated by the client company, and a compensation lawsuit was filed against … A.Ş. with the file numbered …/… of the … Court. (Appendix 3) This lawsuit for compensation was concluded on …/…/… decided to be borne by
3-) For these reasons we have explained, Article 89/3 of the Execution and Bankruptcy Law No. 2004. In order to determine that the client is not indebted to the follow-up debtor … A.Ş.
LEGAL REASONS :
LEGAL EVIDENCE: Enforcement follow-up file, the contract signed between the parties, dated ……………, the decision of the Court of …/…, expert examination, witness statements (names and addresses will be notified to the court if requested).
CONCLUSION AND CLAIM: For the reasons we explained above, it has been determined that my client does not owe the debtor … A.Ş. On behalf of our client, we respectfully request that he be sentenced to bad faith compensation, and that the litigation expenses and attorney’s fees be charged to the other party. …/…/…
ANNEXES: 1……Executive Directorate …./…. Tracking number file
Contract of sale dated …./…..
3……. Court of …./…. Case file no. E.
4. The names and addresses of the witnesses and the subjects they will testify
shows witness list,
5. One certified copy of the power of attorney.
Plaintiff’s Attorney
Lawyer
