…….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 found the debtor’s payment plan appropriate and accepted the request for a concordat.
3-The payments specified in the concordat plan and deemed appropriate by our client have been delayed since the very first one. The debtor has failed to make two payments totaling …….. TL that were due to our client over the past two months. Nevertheless, acting in good faith, our client called the debtor to warn him due to his special circumstances and also sent a warning letter, but the debtor did not respond to the calls or the warning letter.
4-We are compelled to request the termination of the concordat with respect to our client.
LEGAL GROUNDS: Article 307 of the Enforcement and Bankruptcy Code
EVIDENCE: Concordat File, Notice of Default, AND OTHER EVIDENCE.
CONCLUSION: For the reasons stated above, we request that the court decide to terminate the concordat violated by the debtor, that the costs of the proceedings be borne by the defendant, and that the opposing party’s attorney’s fees be awarded 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