Petition In 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 lawsuit.
EXPLANATIONS:
We are the attorneys of ……………. pursuant to the attached power of attorney.
Enforcement proceedings were initiated against the plaintiff ………….. through the Antalya General Enforcement Office ………………. file number, the vehicle with license plate number ………….. belonging to the debtor …………… was seized and taken into custody, and an appraisal was made through the Alanya Enforcement Directorate …………. file number.
For the purpose of determining the value of the vehicle, according to the valuation report dated …………….. prepared by Mechanical Engineer …………………, since the vehicle did not have a key and its doors were locked, the engine and transmission could not be inspected. Other than this, the examination determined that the vehicle had a second-hand market value of 200,000.00 TL. market value was determined to be 200,000.00 TL.
Since the seized property will be sold by public auction as a result of 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 decision of the Honorable Court regarding the discovery/expert examination, we request that the discovery and expert examination be carried out, the debtor’s objections be evaluated as soon as possible, and a final decision be made. 09.12.2021
LEGAL GROUNDS: The 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,
and that the litigation costs and attorney’s fees be borne by the opposing party, as we did not cause the lawsuit to be filed.
………………….Attorneys
Atty…………………..
