Write a petition similar to this sample, add sentences, and include a title

… Enforcement Directorate
File Number: …/…
TO THE DUTY PRIMARY COMMERCIAL COURT,
ANKARA

PLAINTIFF:
[Name and Surname] – (Turkish Republic Identity Number: [Turkish Republic Identity Number]) – Address

ATTORNEY:
Lawyer [Name and Surname] – Address, Mobile Phone: [Mobile Phone Number]

DEFENDANT:
[Name and Surname] – Address

SUBJECT:
Submission of our request for the annulment of the defendant debtor's malicious objection to the file numbered …/… of the … Enforcement Directorate, for the continuation of the enforcement proceedings, and for a 20% compensation payment.

EXPLANATIONS:

1. The defendant debtor, ... (debtor in the file numbered .../... of the ... Enforcement Directorate), purchased flour from the client company. However, as can be seen from the current account statement, the defendant debtor has not paid the debt of ... TL that is the subject of the enforcement proceedings.
2. The defendant debtor purchased a total of eight goods from the client company on …/…/… based on an oral sales agreement, consisting of … mini scissor trailers, … mini non-scissor trailers, and … mini manual dump trailers with gearboxes, totaling … TL and numbered ….
3. Despite a notice being sent to the defendant debtor on …/…/… demanding payment for the goods, the payment due date of … months and … days has passed, but no payment has been made.
4. The defendant debtor's objections are unfounded, unjustified, and improper, and should be dismissed. Examination of the client company's current account statements and the parties' accounting records reveals that the debt in question remains unpaid.
5. The defendant's objections are unjust and lack legal basis, and are solely aimed at delaying the collection of the debt. The debt is a liquid asset, and the defendant's malicious objection has halted the collection process, causing harm to our client company. For these reasons, we request that the defendant be ordered to pay enforcement denial compensation of no less than 20% of the debt amount.

EVIDENCE:

1. ... Enforcement Directorate's file numbered .../... (we request its summons from the enforcement directorate)
2. Witness statements
3. The parties' commercial books and records
4. Expert examination
5. Supreme Court rulings and all kinds of evidence

LEGAL GROUNDS:
Turkish Commercial Code and related legislation.

CONCLUSION AND REQUEST:
Based on the matters presented and explained above, and those to be considered ex officio; reserving our rights regarding further claims,

1. With the acceptance of our rightful claim, the defendant debtor's unjust and malicious objection to the file numbered …/… of the … Enforcement Directorate is annulled, and the enforcement proceedings shall continue
2. Since the enforcement proceedings have been suspended and the receivable is liquid, a penalty for denial of execution shall be paid, not less than 20%
3. We respectfully request and demand, on behalf of our client, that the court order the defendant to pay the court costs and attorney's fees.

…/…/…
Plaintiff's Attorney, Attorney
[Name and Surname]
Signature

APPENDICES:

1. Power of attorney
2. … Enforcement Office …/… E. numbered Enforcement File (We request its retrieval from the Enforcement Office.)