…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : TERMINATION OF THE CONCORDAT
EXPLANATIONS :1-Upon the request of the opposing party, the debtor was granted a 40-day concordat period by the decision dated …….nce …….
2-Subsequently, upon the debtor’s application, the court found the debtor’s payment plan appropriate and accepted the concordat request.
3-Our investigations revealed that the debtor owns one 2001 Mercedes passenger car with license plate number .. .. … and two villa cooperative shares registered in the debtor’s name in Çeşme. Furthermore, witnesses have confirmed that the debtor, following the court’s decision to accept the concordat, has been enjoying luxury entertainment venues daily and traveling to Cyprus for gambling on weekends.
4-It is clear that the defendant has victimized our client, who has a finalized claim against the debtor in file no. ……. E, as well as all of his creditors, and has misled the official authorities. We will also file a complaint with the Chief Public Prosecutor’s Office in this regard.
5-We request that Your High Court revoke the approved concordat on behalf of the debtor.
LEGAL GROUNDS: IİK AND OTHER LAW PROVISIONS.
EVIDENCE: Concordat File, Enforcement File, Cooperative Records, and all other evidence.
CONCLUSION: We request that the court decide to terminate the approved concordat for the reasons stated, that the defendant bear the costs of the proceedings, 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