… TO THE PROSECUTOR’S OFFICE
Page:
TURKISH IDENTIFICATION NUMBER:
ADDRESS:
ATTORNEY:
ADDRESS:
SUSPECTED MUFTIS:
Charge: Fraudulent bankruptcy.
DATE OF OFFENSE: …/…/…
INSTRUCTIONS:
1 -) The suspect…… is the owner of the company. He had a business relationship with our client for a period of time. Our client… … sold construction materials to the suspect, to be delivered within six months….. He received a check number from the bank….. (October 1)
2 -) Three months after the commencement of this business relationship between our client and the suspect on …/…/…, the suspect declared bankruptcy, and the suspect’s bankruptcy was finalized by a decision of the Commercial Court. (October 2)
3) However, the suspect mufti… transferred two apartments registered in his name to his ex-wife before the Commercial Court’s bankruptcy decision… (October 3). If the case file of the aforementioned individual—who is divorced—is reviewed by the Family Court…/…. E. …./…. K., this will also be evident to the court. (October 4)
4 -) It is clear that the mufti acted with the intent to conceal assets from his creditors. He expended his assets by entrusting them to his ex-wife.
5-) For the reasons stated above, an investigation must be conducted to punish the mufti, who has clearly caused harm to our client through a sham sale, and a public lawsuit must be filed against him.
Legal grounds: 2004 Civil Code Art. 311, Turkish Penal Code Art. 161
Evidence: A copy of a check issued as a result of the purchase and sale transaction between our client and the muftis; a copy of a bankruptcy ruling issued against the muftis; the case file of the Family Court dated December… No. …/… Case file, Land Registry records regarding the transfer
Conclusion and Request: For the reasons outlined above, we respectfully request that a public prosecution be initiated on behalf of our client and that the necessary investigation be conducted to punish the individual who transferred our client’s real estate to his divorced spouse with the intent to defraud our client. …/ …/ …
ATTACHMENTS:
1 -) A photocopy of a numbered check held at … Bank as a result of the purchase and sale transaction between our client and the bankrupt party.
2 -) A copy of a bankruptcy ruling issued by the … Commercial Court, …/… main, …/… decision number.
3 -) Land Registry records regarding the transfer of property
4 -) … Family Court … case number
3 -) A copy of a certified power of attorney
Attorney Filing the Complaint
Attorney.