ANKARA ON-CALL EXECUTION CRIMINAL COURT
COMPLAINANT
(CREDITOR):
ATTORNEYS:
DEFENDANT
(DEBTOR):
SUBJECT: Our request for the punishment of the debtor who has failed to pay alimony.
CRIME: Failure to comply with the decision regarding alimony in accordance with Article 344 of the Enforcement and Bankruptcy Law
EXPLANATIONS:
1- The parties were divorced by the decision of the Ankara 6th Family Court dated … with case number … E. – … K. (ATTACHMENT-1) The decision was appealed by our party.
2- Pursuant to the decision issued by the Ankara 6th Family Court, the client was awarded 1,000.00 TL in interim alimony from the date of the lawsuit until the date of the decision, and 600.00 TL in interim alimony effective from the date of the decision. (ATTACHMENT-2)
3- Pursuant to this decision, enforcement proceedings have been initiated from the Ankara 1st Enforcement Directorate’s file numbered … E.
5- The debtor has failed to make alimony payments for September, October, and November 2021, and it has become necessary to file this lawsuit.
LEGAL GROUNDS: Enforcement and Bankruptcy Code and other relevant legislation
EVIDENCE: Subject to our right to present evidence against the opposing party’s evidence;
1- The ruling of the Ankara 6th Family Court, file no. … E. – … K. (Appendix 1)
2- Ankara 1st Enforcement Directorate file no. … E. (We request a copy.)
3- And any other legal evidence.
CONCLUSION AND REQUEST: For the reasons explained above, we request that the debtor who has failed to pay alimony be punished in accordance with Article 344 of the Enforcement and Bankruptcy Code, and that the costs of the proceedings and attorney’s fees be imposed on the defendant. Respectfully submitted. …/…/..
Plaintiff’s Attorney
Attorney at Law
