Response to the Valuation Objection Case
TO THE 1ST EXECUTION COURT OF ALANYA
FILE NO.: ………
DEFENDANT: ………..
ATTORNEYS: Attorney ……………..
PLAINTIFF: …………….
SUBJECT: Submission of our response to the case.
EXPLANATIONS:
We are the attorneys for the company ……………. pursuant to the attached power of attorney.
Enforcement proceedings were initiated against the plaintiff ………….. under file number ………………. at the Antalya Enforcement Directorate, the vehicle with license plate ………….. belonging to the debtor …………… was seized and taken into custody, and an appraisal was made under file number …………. at the Alanya Enforcement Directorate.
According to the expert report dated …………….. prepared by Mechanical Engineer ………………… for the purpose of determining the value of the vehicle, the engine and transmission could not be inspected because the keys were missing and the doors were locked. Other than that, the inspection determined that the vehicle’s second-hand market value was 200,000.00 TL, and its market value was 200,000.00 TL.
Since the seized property will be sold by auction as a result of the enforcement proceedings, it is clear that the plaintiff debtor will not suffer any loss of rights. The plaintiff has no legal interest in objecting to the valuation.
However, in line with the Court’s decision regarding the discovery/expert examination, we request that the discovery and expert examination be carried out, that the debtor’s objections be evaluated as soon as possible, and that a final decision be made. 12/09/2021
LEGAL BASIS:
Enforcement and Bankruptcy Law and other relevant legislation.
EVIDENCE: Discovery, expert witness, witness statements, and all other types of evidence.
CONCLUSION AND REQUEST: For the reasons stated and explained above;
We submit our response to the lawsuit and respectfully request that the valuation be redone by an expert witness.
Since we did not cause the lawsuit to be filed, we request that the litigation costs and attorney’s fees be borne by the opposing party.
………………….Attorneys
Attorney…………………..