…… Court

PLAINTIFF :

Acting :

ADDRESS :

DEFENDANT :

ADDRESS :

Subject: our statements about the case.

INSTRUCTIONS

1 -) defendant, our client… against, we have made to him … TL.despite the payment of …TL.due to the beginning of execution proceedings with the mortgage certificate, we have filed a lawsuit and requested that the execution be reinstated due to the performance of the debt.

2 -) however, the defendant, …/…/… we are in the trial dated …TL.although he agreed to pay, he stated at the hearing that this debt had not been paid.

3 -) it is indisputable that the extension or modification of the defence after the merits of the case are subject to the consent of the opposing party. We are also the opposite party ‘… TL. we do not consent to him extending his plea as unpaid. As a matter of fact, we pay …TL.we offer payment receipts related to the business with this petition.

Legal reasons: 1086 P. K. m. 202, 33 and related legislation.

Legal evidence: payment receipts, witness statements and other evidence.

RESULT AND PROMPT

For the reasons described above, we do not agree with the defendant to extend his / her plea that the debt was not paid at the trial date.’cause of the payment. m. 33 in accordance with the provisions, we demand and demand that the execution be put back until the end of the case, that the costs of the trial be imposed on the defendant, and that the decision be made.