… TO THE HONORABLE COURT
PLAINTIFF:
ATTORNEY:
DEFENDANTS:
SUBJECT: Our request for the dissolution of the company named …
EXPLANATIONS
1- Our client … and the defendants … and … established … Marketing Limited Company, as published on … page of … Newspaper No. … on …/…/….
2- According to the decisions recorded on page .. of the company’s decision book, certified by the Notary Public of … on … with journal no. …, and bearing decision serial no. …, dated …/../…. meeting, all three partners were elected as company directors for a term of 20 years.
3- Due to the other two defendants being engaged in other business, my client carried out the task of collecting receivables and distributing them to the others. However, even though my client distributed the receivables he collected to the two defendants as required, they sent a Notice of Default dated ../../…. and numbered …… from the … Notary Public to my client.
4- In the notice they sent to my client, the defendants claimed that he had not paid the company what he had collected and demanded that ……….-Turkish lira be paid in cash to the company headquarters.
5- The defendants’ actions portray our client as a thief and are a label against our client, who has delivered all the money he has collected to date to the company and collected it fairly.
6- Our client has not received any documentation for all the money he has collected to date. The money collected by our client and delivered to the company headquarters has not been recorded in the official records.
7- The defendants’ real aim is to put our client, who has asked the company partners for an accounting, in an unfair position and to use him. These types of companies are commercial companies established based on trust between partners. As can be understood from the warning letter sent by the defendants to our client, the defendant partners accuse our client of theft. As a result of this warning letter, our client has lost trust in the company partners.
8- Such accusations are grounds for termination of the partnership with just cause under Article 549/4 of the Turkish Commercial Code. Since the company partners no longer trust each other and it is impossible for the company to continue under these circumstances, it has become necessary to apply to your court for the dissolution of the company.
LEGAL GROUNDS: Article 549/4 of the Turkish Commercial Code, Code of Civil Procedure, and relevant legislation.
EVIDENCE: company records, witnesses, formal notice.
RESPONSE PERIOD: .. days
CONCLUSION: For the reasons stated above, since the company partners no longer trust each other and it is not possible for the company to continue under these conditions, we request that the dissolution of … Ltd. Şti. be ordered for just reasons, that the litigation costs be borne by the defendant, and that the attorney’s fees of the opposing party be awarded to us as attorneys in accordance with the … amended by Law No. …, we request that the opposing party’s attorney’s fees be awarded to us as attorneys. …/…/…
PLAINTIFF’S ATTORNEY