Sample Petition To Initiate A Lawsuit For Breach Of Contract
TO THE ANTALYA ON-CALL ENFORCEMENT AND CRIMINAL COURT,
COMPLAINANT : …… Inc.
ATTORNEY : Attorney ……..
DEFENDANT (DEBTOR) : ……….. (Turkish ID No. ……….)
…………..
CHARGE : BREACH OF CONTRACT
DATE OF COMMITMENT : Installments dated July 22, 2020; August 22, 2020; and September 24, 2020
SUBJECT OF THE CASE : A request to impose a 3-MONTH PRISON SENTENCE
on the debtor-defendant for breaching his commitment.
EXPLANATIONS :
Pursuant to the attached power of attorney and authorization document, we are the attorneys for ………….
Enforcement proceedings have been initiated by the Antalya ……… Enforcement Office under case no. ………. E. regarding the bank’s claim against ………..
The debtor/defendant ………., in Case No. ……….. of the Antalya ………. Office, has undertaken to pay the entire debt in monthly installments beginning on January 23, 2020. However, the debtor failed to make the installments due on July 22, 2020, August 22, 2020, and September 24, 2020, without any valid reason. The debtor has breached his commitments. This fact is established by the relevant enforcement file.
Consequently, since the debtor has violated Article 340 of the Enforcement and Bankruptcy Code, it has become necessary to file this complaint.
LEGAL GROUNDS: Article 340 of the Enforcement and Bankruptcy Code, applicable laws, and case law.
EVIDENCE: The enforcement file No. ……….. E. of the Antalya …….. Enforcement Office
and all other evidence.
CONCLUSION AND REQUEST : As counsel, we respectfully request that the debtor-defendant, who has breached his undertaking, be SENTENCED TO 3 MONTHS’ IMPRISONMENT, and that all litigation costs and attorney’s fees be imposed on the opposing party. Respectfully submitted.
ATTACHMENTS :
Power of Attorney and Authorization Certificate
Minutes of the Undertaking.
Attorneys,