… … TO THE ENFORCEMENT COURT
Plaintiff:
TURKISH IDENTITY NUMBER:
ADDRESS:
LAWYER:
(Legal representatives of the parties, if any)
ADDRESS:
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS:
SUBJECT: Our objection to the valuation.
OUR EXPLANATIONS:
1-) The defendant has seized the property registered at the Land Registry Office due to our client’s debt to him. The value of our client’s property has been appraised as ….-TL (…).
2-) However, it is evident that the value of our client’s property is significantly lower than the value of comparable properties in the same location. The current value of our client’s property is … TL. This will also be evident from the expert examination.
3-) It has become necessary to apply to your court for the re-determination of the aforementioned value assigned to the property.
LEGAL GROUNDS: 2004 NK Art. 128/A.
LEGAL EVIDENCE: 1-) Sales contracts for similar properties,
2-) Witness
CONCLUSION AND REQUEST: For the reasons explained above, we request that the real estate of our client be re-appraised by an expert, that the litigation costs and attorney’s fees be imposed on the defendant, and that a decision be made in favor of our client. …/…./….
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