… TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE
PLAINTIFF : TC No:
address :
attorney :
address :
DEFENDANT :
ADDRESS :
SUBJECT : …. Executive directorate …/… E. our debtor in the numbered file …..’earth …. Bank…. It includes our request to remove the block placed on the defendant bank’s account at the branch and consists of the submission of our petition.
OUR EXPLANATIONS
1-) Our client, …. Executive directorate …/… e. the debtor with the numbered file … …. having initiated enforcement proceedings against him, the follow-up was finalized on the date of … /… / … and our client also requested foreclosure on the date of … / … /… by the enforcement directorate of the debtor …. Bank…. A statement about the seizure of your account in the branch …. Bank…. The branch has been notified.
2-) Upon the notification of the foreclosure order to the defendant bank, the bank sent a response letter to the enforcement office on the date of … /… /… “The account is requested to be foreclosed …. Executive directorate …/… e. the debtor of the numbered file … /…/… from the bank on the date of …….. The last of the loan installments in accordance with the agreement between them and the bank, from which they took out a housing loan in the amount of TL . Dec… it was stated that the money contained in the account that was requested to be foreclosed due to non-payment of the installment was blocked by the bank and it was stated that it was not possible to pay a foreclosure on the account.”
3-) Although the defendant bank …. Executive directorate …/… e. although he stated that no foreclosure could be placed on the debtor’s account of the numbered file, in accordance with the loan agreement between the bank and the debtor, the Decedent established a mortgage on a real estate in favor of the bank based on the loan he had taken out. For this reason, there is a mortgage facility in favor of the bank to cover its receivables, and since the bank has no obligation to cover its receivables from the foreclosed account, there is an explanation that the block placed on the account is inappropriate.
4-) All that is explained is therefore the bank …. Executive directorate …/… e. the debtor of the numbered file has been obliged to request the removal of the block he has placed on his account with this petition.
LEGAL REASONS : 2004 P. K. m. 85,86; 6100 Pp. K. m. 2, 6, 14.
LEGAL EVIDENCE: 1-) The foreclosure letter sent to the bank
2-) …/…/… Dated Bank’s Response Letter
3-) …/…/… Housing Loan Agreement
4-) … … The Executive Directorate of … / … E. numbered file
CONCLUSION AND CLAIM : For the reasons described above …. Executive directorate …/… e. we request by proxy on behalf of our client to decide to remove the block placed by the defendant bank on the debtor’s account of the numbered file, and to transfer all trial expenses and attorney’s fees to the other party. …/…/…
ADDITIONAL:
Plaintiff Attorney
Lawyer.
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