…….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 accepted the concordat request, finding the debtor’s payment plan appropriate.
3-The payments specified in the concordat plan, which our client also found appropriate, 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 them due to their 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 composition agreement with respect to our client.
LEGAL GROUNDS: Article 307 of the Enforcement and Bankruptcy Law
EVIDENCE: Conciliation 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