ANTALYA ON DUTY ENFORCEMENT CRIMINAL COURT,
COMPLAINANT : …… A.Ş.
DEFENDANT : AV. ……..
DEFENDANT (DEBTOR) : ……….. (T.C. ……….)
…………..
CRIME : BREACH OF COMMITMENT
COMMITMENT DATE : 22.07.2020-22.08.2020 -24.09.2020 dated instalments
SUBJECT OF THE CASE : 3 months imprisonment for the debtor-defendant who violated his commitment is the request to be given.
EXPLANATIONS :
We are the attorneys of …………. in accordance with the attached power of attorney and authorisation certificate.
Due to the receivable of the client bank from ……….., the Antalya ……… Enforcement Office’s ………. E. numbered execution file of Antalya Execution Office.
The debtor/defendant ………. has undertaken to pay the entire debt in monthly instalments starting from 23.01.2020 in the file numbered ……….. of Antalya ………. Office. However : 22.07.2020-22.08.2020-24.09.2020 dated instalments without a justifiable reason. The debtor has violated its commitments. This situation is fixed with the relevant enforcement file.
Thus, since the debtor has violated Article 340 of the BEC, it has become necessary to file this complaint.
LEGAL GROUNDS : Article 340 of the BEC, laws and case law.
EVIDENCE : Antalya …….. Execution Office ……….. E. numbered execution file and all kinds of evidence.
CONCLUSION AND REQUEST:
We request and demand as an attorney that the debtor-defendant who violated his commitment be sentenced to 3 months imprisonment, and that all trial expenses and attorney fees be charged to the other party. Sincerely.
ANNEXES :
Power of Attorney and Authorisation Certificate
Letter of Undertaking
REPRESENTATIVES
….
You can access our other article examples and petition examples by clicking here.