ANTALYA PEACE COURT OF LAW TO THE HONORABLE JUDGE
ENFORCEABILITY
PLAINTIFFS
PLAINTIFF: …………..
ATTORNEY: Attorney………………
OTHER PARTY: ……………..
ADDRESS: …………………..
SUBJECT OF THE REQUEST
MEDIATION
DOCUMENT: Antalya Mediation Office, …………. Mediation
………….. Office No., Mediation Agreement Document
SUBJECT: Our request is for an enforceability clause to be added to the Mediation Agreement
document, the details of which we have provided.
EXPLANATIONS:
1- ANTALYA Mediation Office, …….. Mediation
……….. Office No., Mediation Agreement Document, and the Mediation Agreement Document dated 11.06.2021 (Final Mediation Agreement Minutes), which we have submitted as an attachment, was drawn up after discussions and agreement with Mediator ………..
2- Pursuant to this Mediation Agreement Document;
………………….; ………………ANTALYA …….Enforcement Directorate’s ………..E. numbered file, will pay 186,960.00 TL (One hundred eighty-six thousand nine hundred sixty Turkish Lira), excluding fees and expenses, in exchange for the relevant receivable. This payment shall be made in two equal installments to the account with the TR …………………. IBAN number held at the İŞ BANKASI ………………. BRANCH by the representative Av…………….. of …………….., unconditionally and without reservation.
The payment of 186,960.00 TL by ……………… shall be made in two equal installments:
First Payment: 93,480.00 TL on …………….
Second Payment: 93,480.00 TL on ……………..
Although it was agreed that the payments would be made, ………………. has not made the payments in full and on time.
3- For the reasons stated above, we are obliged to request that the aforementioned Mediation Agreement be declared enforceable pursuant to Article 18, Paragraph 3 of the Mediation in Legal Disputes Law No. 6325.
LEGAL GROUNDS: Law No. 6325 on Mediation in Legal Disputes,
Turkish Commercial Code No. 6102, Code of Civil Procedure, and related legislation.
EVIDENCE: The Mediation Agreement and other evidence submitted in the attachment.
CONCLUSION AND REQUEST:
For the reasons stated and explained above, and for the reasons that the Honorable Court will consider ex officio, we respectfully request that a decision be made to issue an enforceability clause for the mediation agreement dated 11.06.2021, submitted as an attachment.
Requesting Party
…………..
Attorney……………………..
