TO THE HONORABLE COURT
…….
PLAINTIFF :…….
LAWYER :…….
THE ACCUSED: …….
SUBJECT: TERMINATION OF THE CONCORDAT
EXPLANATIONS:
1-To the debtor at the request of the other party……. With the dated decision, the concordat period of 40 days has been given.
2-Later, upon the debtor’s application, your court approved the. Pay plan of the debtor and accepted the concordat request.
3-The payments specified in the concordat plan and deemed appropriate by our client have been delayed from the very beginning. Paid paid to our client in the last two months…… The debtor has not made two payments in the amount of TL…… The total amount to be paid to our client in the last two months. Despite this, our client, in good faith, called the debtor and warned him about his special situation and also sent a warning, but the debtor did not respond to either the calls or the warning.
4-We had to request the termination of the concordat on behalf of our client.
LEGAL REASONS: 307 of the Execution and Bankruptcy Code. article
EVIDENCE: Concordat File, Warning Letter AND OTHER EVIDENCE.
REQUEST: We request that it be decided to terminate the concordat violated by the debtor for the reasons mentioned above, to charge the trial expenses to the defendant, and to pay the opposing party’s attorney fee to us as a proxy in accordance with the last paragraph of Article 164 of the Attorney’s Law No. 1136, amended by Law No. 4667.
THE PLAINTIFF’S LAWYER