Example of a Negative Declaration Case Petition
THE COURT OF FIRST INSTANCE
(an injunction has been requested)
prosecutor:
PLAINTIFF’S LAWYER :
THE DEFENDANT:
THE SUBJECT OF THE CASE : ……….. It is negative declaration case aimed at determining that my client is not in debt.
EVENTS : 1- My client ………… In his history, defendant A bought a Bürüsit brand office chair and a work desk from A. And …….. (……) TL …… paid. (………) TL in advance and………. The dated promissory note has been arranged. for the rest of the part.
2- Although my client has paid the above-mentioned kaan debt on time, the defendant …. By calling my client …….. (………) He threatened to say that he had to pay the TL debt, otherwise he would put the promissory note into execution. However, the promissory note is fake and my client has paid the entire debt in question.
3- Since the defendant…. He can put in the promissory note indicated by the defendant…. It has become mandatory to initiate enforcement proceedings and to open this negative declaration case with an injunction against collateral.
LEGAL BASES:
EVIDENCE: Promissory note, receipt of paying my client’s debt. Expertise and all kinds of legal evidence if necessary.
CONCLUSION AND REQUEST : With the acceptance of our case for the reasons mentioned above, we sincerely request and request that it be decided to determine that my client is not the debtor of the promissory note in question, to issue an injunction not to put the promissory note into enforcement proceedings in exchange for collateral in order to prevent the collection of the promissory note. prevention of enforcement proceedings and loading of attorney’s fees and trial expenses to the defendant. ../../..
Plaintiff Lawyer
Lawyer. …………….
(SIGNATURE)
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