… VISITING COURT …
(Request for Precautionary Measures)
Plaintiff: Name-Surname (TC ID No: …)
ATTORNEY: Attorney … (If you have an attorney, write your attorney’s information here)
DEFENDANT: Name-Surname (TC ID No and address, if known)
SUBJECT OF THE CASE: Request for Negative Determination.
VALUE OF THE CASE: … TL
EXPLANATIONS:
1- On …/…/……. an enforcement proceeding was initiated against the defendant by the Enforcement Directorate under number …/…..
2- The plaintiff has no debt to the defendant for any of the … reasons. However, due to the enforcement proceedings initiated by the defendant, it has become necessary to file a negative determination lawsuit.
LEGAL GROUNDS: Article 72 of the Enforcement and Bankruptcy Law and other relevant legislation.
LEGAL EVIDENCE: Enforcement Directorate enforcement file, witness statements, guarantees, and other relevant evidence.
CONCLUSION AND CLAIM: For the reasons explained above, I request that it be determined that I have no debt to the defendant, that the proceedings be suspended and a precautionary measure be issued, that the defendant, who acted in bad faith, be ordered to pay 20% compensation, and that the costs of the proceedings be borne by the defendant. …/…/…