Petition For Termination Of Concordat 2
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- In the investigations made by us, 1 … … … license plate numbered Mersedes Brand 2001 model passenger car belonging to the debtor and 2 Villa Cooperative shares registered in the name of the debtor in Çeşme were determined. In addition, it has been determined by the witnesses that the debtor had fun in luxury entertainment places every day with the court’s decision to accept the concordat and went to Cyprus to gamble on weekends.
4-The defendant’s creditors and, of course, the debtor’s ……. of ……. It is obvious that he victimized our client, who has a finalized receivable from the debtor with the file numbered E, and misled the official authorities. We will also file a complaint to the Chief Public Prosecutor’s Office on this matter.
5- We request your supreme court to annul the concordat approved on behalf of the debtor.
LEGAL GROUNDS : IİK AND OTHER ARTICLES OF LAW.
EVIDENCE : Concordat File, Execution File, Cooperative Records and all kinds of evidence.
RESULT OF THE REQUEST : For the reasons stated above, we request that the concordat which has been approved be decided to be terminated, 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