TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT: …….
SUBJECT: TERMINATION OF CONCORDAT
EXPLANATIONS: 1-At the request of the opposing party, the debtor was granted a 40-day concordat period by the decision dated …….
2-Subsequently, upon the debtor’s application, your court approved the debtor’s payment plan and accepted the concordat request.
3-The payments specified in the concordat plan and deemed appropriate by our client have been delayed since the very beginning. The debtor has failed to make two payments totaling …….. TL that were due to our client over the past two months. Nevertheless, our client, acting in good faith, called the debtor to warn him of his special circumstances and also issued a warning, but the debtor did not respond to the calls or the warning.
4-We have been forced to request the termination of the concordat on behalf of our client.
LEGAL REASONS: Article 307 of the Enforcement and Bankruptcy Law
EVIDENCE: Concordat File, Warning Letter, AND OTHER EVIDENCE.
REQUEST: Based on the aforementioned reasons, we request that the court decide to terminate the concordat violated by the debtor, impose the litigation costs on the defendant, and order the payment of the opposing party’s attorney’s fees to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY
