-SAMPLE Petition-
ANKARA ON DUTY ( ) TO THE EXECUTIVE JUDGE
WITHDRAWAL OF EXECUTION
REQUESTED
APPLICANT (DEBTOR)
ADDRESS :………
ATTORNEY:
ADDRESS :
TELEPHONE :
DEFENDANT (CREDITOR):
ADDRESS :………………………
SUBJECT OF THE REQUEST: It is our request to adjourn the enforcement proceedings made with the file numbered 2021/….. of the Ankara ….Executive Directorate.
DESCRIPTIONS
A verdict was initiated by the creditor against the plaintiff client A….. B….. over the file numbered 2021/….. of Ankara ….Execution Directorate (ANNEX-1), and the execution order was sent to us ../../…. communicated on.
We submit our requests regarding the adjournment of execution pursuant to Article 33 of the EBL, within the legal period, as follows. Namely;
Pursuant to Article 39 of the EBL, “Proceedings based on judgment become time-barred after ten years have passed since the last treatment.” is called. The writ subject to proceedings is between the plaintiff client and the defendant creditor ../../…. The bill amounting to ….. TL was issued on date (Annex-2).
As a result, this pursuit, which was initiated against the procedure and the law, is malicious and unfair. There is no such debt of the client. For all these reasons, the issue of requesting the adjournment of this unjust execution proceeding initiated against the client has occurred to us.
LEGAL REASONS: İİK (33-39 and all other articles), HMK, Atty. Law and other relevant legislation
EVIDENCE: Subpoena of Ankara …. Enforcement Directorate’s file numbered 2021/….. E., promissory note dated ../../…., Expert report (if deemed necessary), All kinds of other evidence
CONCLUSION AND REQUEST: For all the reasons explained above and to be taken into account by your Court ex officio,
1-Delaying the enforcement proceedings initiated against the plaintiff client A….. B….. pursuant to article 33 of the EBL,
2- We supply and demand that it be decided to leave the litigation expenses and attorney’s fee to the other party. 14/09/2021
Requesting a Delay of Execution
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