TO THE HONORABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : TERMINATION OF CONCORDAT
EXPLANATIONS :1-With the request of the debtor counterparty, the debtor was granted a 40-day concordat respite with the decision dated …….nce ……..
2-Then, upon the application made by the debtor, the payment plan made by the debtor was found appropriate by your court and the concordat request was accepted.
3- The payments specified in the concordat plan and deemed appropriate by our client have been disrupted starting from the very first one. The debtor has not made two payments to our client in the last two months, amounting to a total of ……..-TL. Nevertheless, our client, acting in good faith, called the debtor to warn him due to his special situation and also sent a warning, but the debtor did not respond to the calls and warnings.
4- It has been necessary to request the termination of the concordat in terms of our client.
LEGAL GROUNDS : Article 307 of the BEC
EVIDENCE : Concordat File, Cease and Desist Notice and OTHER EVIDENCE.
CONCLUSION OF THE REQUEST : For the reasons explained, we request that the termination of the concordat violated by the debtor be decided, that the costs of the proceedings be charged to the defendant, and that the counterparty attorney fee be awarded on our behalf as an attorney in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
…….
