…… TO THE COURT
PROSECUTOR:
ATTORNEY:
ADDRESS:
DEFENDANT:
ADDRESS:
SUBJECT: Our Explanations Regarding the Case.
INSTRUCTIONS
1-) We filed a lawsuit against the defendant for … TL on behalf of our client. Despite the payment of … TL, we filed a lawsuit for the cancellation of the execution on the grounds of debt fulfillment due to the initiation of enforcement proceedings with a mortgage deed.
2-) However, during the hearing on … TL, the defendant stated that the debt had not been paid, even though he had accepted the payment in our presence.
3-) It is an indisputable rule that the expansion or modification of the defense is subject to the other party’s consent after the merits of the case have been presented. And we are on the other side of the ‘… TL’. We do not agree with the expansion of the defense as ‘not paid’. In fact, we made a payment of … TL. We are submitting the payment receipts related to the transaction along with this petition.
LEGAL GROUNDS: 1086 PK m. 202, 33 and related legislation.
LEGAL EVIDENCE: Payment receipts, witness statements and other evidence.
CONCLUSION AND REQUEST
For the reasons explained above, we did not accept the defendant’s defense that the non-payment of the debt was due to negligence at the hearing dated /…/…. The creditor, …TL., due to the initial payment being made, will request the lifting of enforcement until the end of the case, the transfer of the trial costs to the defendant, and a decision to be made in accordance with the provisions.
Plaintiff’s Attorney