Petition for the Return of the Original Check to the Debtor Due to External Collection

… TO THE ENFORCEMENT DIRECTORATE,
ANKARA

FILE REFERENCE NUMBER: …/…

CREDITOR:
Name and Surname – (Turkish Republic Identity Number: …) – Address

ATTORNEY:
Lawyer's Name and Surname – Address

DEBTOR:
Name and Surname – Address

SUBJECT:
Return of the original check to the debtor due to external collection and lifting of the lien on the vehicle with license plate number …

EXPLANATIONS:

1. Enforcement Proceedings and Collection Status: ... In the enforcement proceedings we initiated against the debtor with file number .../... of the Enforcement Directorate, the entire amount of our receivable has been collected by us through private means. This is confirmed by various documents documenting all transactions carried out within the scope of the file and the private collection.
2. Collection Fee and Refund Request: For debts collected externally, the original check must be returned to the debtor, provided the debtor pays the collection fee. The return of the original check to the debtor will be considered official documentation confirming the debtor's fulfillment of their obligations.
3. Lifting the Seizure: We also request the lifting of the seizure previously placed on the vehicle with license plate number … belonging to the debtor. This seizure should be lifted to prevent the debtor from suffering any loss of rights due to the debt being collected externally by the creditor.
4. Procedures Required: In accordance with the matters explained above, we request that the necessary procedures be carried out to ensure the return of the original check to the debtor and the lifting of the lien on the vehicle, along with documentation proving payment of the amount of the debt collected externally and the collection fee.

EVIDENCE:

1. Documents relating to receivables collected externally,
2. Documents relating to payment of collection fees for the return of the original check to the debtor
3. Documents showing the lien on the vehicle,
4. Other relevant legal evidence.

LEGAL GROUNDS:
The Enforcement and Bankruptcy Law and other relevant legislation.

CONCLUSION AND REQUEST:
For the reasons explained above;

1. In accordance with the documents proving that the externally collected receivables and collection fees have been paid, the original check subject to the collection proceedings should be returned to the debtor
2. We request the removal of the lien on the vehicle with the registration number … belonging to the debtor
3. I respectfully request and demand that the court order the defendant to pay the court costs and attorney's fees.

…/…/…

Creditor's Representative
Attorney's Name and Surname
Signature