ANTALYA CIVIL COURT OF FIRST INSTANCE TO THE HONORABLE JUDGE
APPLICABILITY
PLAINTIFFS
PLAINTIFF: …………..
ATTORNEY: Attorney………………
OPPOSING PARTY: ……………..
ADDRESS: …………………..
SUBJECT OF THE REQUEST
MEDIATION
DOCUMENT: Antalya Mediation Office, …………. Mediation
………….. Office No., Mediation Agreement Document
SUBJECT: Our request is to add an enforceability clause to the Mediation Agreement.
The document we have provided details for.
EXPLANATIONS:
1- ANTALYA Mediation Office, …….. Mediation
……….. Office No., Mediation Agreement Document and the Mediation Agreement Document dated 11.06.2021 (Final Mediation Agreement Record) submitted in the attachment were prepared as a result of the discussions and agreement made with Mediator ………..
2- Pursuant to this Mediation Agreement Document;
…………………….; ………………ANTALYA …….Enforcement Directorate’s file no. ………..E., it has been decided that a payment of 186,960.00 TL (one hundred eighty-six thousand nine hundred and sixty Turkish Lira), excluding fees and expenses, shall be made for the collection of the relevant receivable. This payment shall be made unconditionally and without reservation in two equal installments by Av…………….., the representative of …………….., to the account with IBAN number TR …………………. at İŞ BANKASI ………………. BRANCH.
The payment of 186,960.00 TL by ……………… will be made in two equal installments:
First Installment: 93,480.00 TL on …………….
Second Installment: 93,480.00 TL on ……………..
Despite reaching an agreement on the payments, ………………. has not made the payments in full and on time.
3- For the reasons stated above, we request that the aforementioned Mediation Agreement be deemed enforceable in accordance with the third paragraph of Article 18 of the Mediation Law in Legal Disputes No. 6325.
LEGAL BASIS:
Law No. 6325 on Mediation in Legal Disputes,
Turkish Commercial Code No. 6102, Code of Civil Procedure, and related legislation.
EVIDENCE: Mediation Agreement and other evidence submitted in the annex.
CONCLUSION AND REQUEST:
For the reasons explained above and to be assessed ex officio by the Honorable Court, we respectfully request that an enforceability clause be added to the mediation agreement dated 11.06.2021, submitted as an attachment.
Requesting Party
…………..
Attorney……………………..