…….TO THE PRESIDENT OF THE COURT
…….
FILE NUMBER:…….
DEFENDANT RESPONDING:…….
ATTORNEY: …….
CLAIM:…….
SUBJECT: This is our response to the complaint.
EXPLANATIONS:
1-The lawsuit filed by the plaintiff is unfounded in terms of procedure and substance. We will submit our response to the lawsuit within. 10 days of the notification of the lawsuit petition.
That is;
a) First of all, the lawsuit was not filed with the competent court. The lawsuit, which should have been filed in the court of our client’s place of residence, was filed in the court of the defendant’s place of residence. Therefore, your court lacks jurisdiction.
b) The lawsuit is subject to a one-year statute of limitations and was filed three years after the statute of limitations expired. For this reason,. We object to the lawsuit on the grounds of the statute of limitations. The lawsuit must be dismissed on the grounds of the statute of limitations.
c) Additionally, it is known that our client ………. is responsible. We know that this person made a payment to the plaintiff in connection with the incident and received a release document. Copies of the release documents are attached. It is unlawful for the plaintiff to demand. This money from our client again years later, having forgotten about it.
2-As can be understood from the reasons explained above, we request that the lawsuit, which was filed in violation of the law, be dismissed both on the merits and on procedural grounds.
RESULT OF THE REQUEST:
We request that our objections be accepted with reasons given, that the case be dismissed, that the costs of the case be borne by the plaintiff, and that the other party’s attorney’s fees be paid by us in accordance with the last paragraph of. Article 164 of Law No. 1136, as amended by Law No. 4667.