………………..THE CIVIL COURT OF FIRST INSTANCE

Plaintiffs :

1)………………………………………………
2)………………………………………………
3)………………………………………………
Deputy: Av. ………………………
DEFENDANT : ……………………………………………….. (execution file creditor )
Deputy: Av………………………
Subject: it is related to the request to determine that the Tereken is submerged in debt.

INSTRUCTIONS :

1. The Muri of our clients………………..TC ID number ……………. …/…/20…. he died in his history.After Muris ‘ death, my clients remained as heirs. ……………since it is known that he did not have any assets at the time of his death, our clients did not reject the legacy of murisin. Following the expiration of the period of refusal of the inheritance, the defendant of the case in question………’muris on the follow-up of the execution initiated by……………….it is understood that tereke of was submerged in debt.
2. ……………there is no real estate or securities of any kind registered on him which may have material value at the time of his death. Client are our heritage …….. ………. at the time of his death, he did not leave any assets of any material value to our clients, nor did he leave many debts.
3. Defendant ………………. by Muris of my clients ………………. against ………. . Executive Directorate Of …….. E. Execution follow-up is started from numbered execution follow-up file, ……………’due to the fact that they are in the position of legal heir due to the death of my clients, payment memorandum has been notified.My clients are therefore faced with paying off the debts of the debt-ridden tereke.
4. The General Assembly of the Supreme Court of law in its decision no.2001/2-220 basis and 2001/240 dated 14/03/2001, in summary, “our Civil Code has registered the genuine rejection of the inheritance for a period of time and provided for a unilateral statement of the will or a course of action by the heirs, but no statement of the will or Moreover, an exception has been made to the rule that rejection is assumed to occur spontaneously and that the inheritance will be transferred to the heirs by opening. In fact, the person who is deemed to have rejected the inheritance by ruling may seek the determination of this situation by turning against the creditors of tereke, or may claim it by way of Def.”the provision was established in the form of.
5. In the same way; the Supreme Court of Law General Assembly dated 16.04.2008, 2008/4-332 basis and 2008/336 Decision No.in summary; “the case is related to the claim for damages rucuen. The dispute is compounded over whether provisions relating to the denial of inheritance should be applied. If the bequeatherís inability to pay is clearly defined or officially determined, the bequeath shall be deemed to have been rejected. There is no need to declare a will or to file a lawsuit in order for a denial of the sentence to result. The person whose inheritance is deemed to have been rejected by the ruling may seek the determination of this situation by inciting animosity against the creditors of tereke, or may claim it by way of defi. It is understood from the scope of the file that the bequeatherâ € ™ s Securities and real estate does not exist, nor does it have any income. In this case, the bequeatherís refusal to pay must be acknowledged to be clear. The decision to dismiss the case on the grounds that the inheritance was rejected by the ruling is in accordance with procedure and law.”The provision was established in the form of. Supreme Court 10. Decision No. 2002/3022 and Decision No. 2002/3315 of the Law Department, Supreme Court 4. Decision No. 2002/1607 of the law department and Decision No. 2002/5992 of the Supreme Court 4. The provisions were similarly established in the rulings of the Law Department 2004/6782 and the decision of 2005-2011.
In the light of the decisions of the General Assembly of law and the Legal Departments of the Supreme Court, it is clear that a lawsuit can be filed against the creditors of the court in order to determine that the court is submerged in debt, that this case is not subject to any period of time, and that the court of first instance is

Muris of my clients for the stated reasons………….we are obliged to open the case at hand in order to determine that the claim of the company is submerged in debt.

LEGAL REASONS: TMK. And other provisions of all legal legislation,
LEGAL EVIDENCE : ……………( )..Executive Directorate 20…./……… E. Numbered follow-up file, inheritance certificate, Land Registry records, traffic records, witness statements, expert examination and all other legal evidence.
Demand and result : we respectfully supply and demand that the inheritance is determined to be submerged in debt for the reasons described above, and the decision is made to remove the heirs of our clients, to charge the prosecution costs and the attorney’s fee to the other party. …/…/20

Acting plaintiffs