Complaint Petition For Breach Of Payment Commitment
-SAMPLE PETITION-
ANKARA SENTENCED ENFORCEMENT CRIMINAL COURT JUDGE
COMPLAINANT
CLIENT :
ADDRESS :……
PROXY :
ADDRESS :
TELEPHONE :
COMPLAINTED
DEBTOR :
ADDRESS :……
SUBJECT OF THE REQUEST :
It consists of our request that the debtor who violated his commitment to the client be sentenced to imprisonment.
EXPLANATIONS
Debtor C…. D… did not pay his debt to our client A…. B…, we initiated enforcement proceedings through the file numbered 2021/….. of Ankara …. Enforcement Directorate Execution proceedings were initiated through the file numbered 2021/ (Annex-1).
With the finalisation of the said proceeding, the debtor undertook to pay the debt for a period to be determined in the presence of the execution manager and with the consent of our party. Accordingly, the debtor ../../…. He undertook to pay his debt by paying 000,00TL per month starting from the date. We have accepted this commitment offer by sending a memorandum of acceptance (Annex-2) to the debtor.
The debtor did not pay the debt on the date of commitment without a justifiable reason for the instalments to be paid. Thus, it has become necessary to apply to your court for the punishment of the debtor who has violated Article 340 of the BEC.
LEGAL GROUNDS :
BEC (Article 340 and all other articles), CCP, Law on Attorneys and other relevant legislation
EVIDENCE :
Ankara ….Execution Directorate’s 2021/….. E. numbered file subpoena, Acceptance memorandum, Expert report (If deemed necessary), Any other evidence
CONCLUSION AND REQUEST:
For all the reasons explained above and to be taken into consideration by your Court ex officio,
1- The suspect debtor C….. who violated his commitment D…. to be sentenced to imprisonment in accordance with the relevant provisions of the Bankruptcy Code,
2- We request and demand that the trial expenses and attorney’s fee be decided to be charged to the suspect. 24/09/2021
Complainant
A…. B…… Acting
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