Bad Cheque Complaint Petition
………… TO THE JUDGE OF THE ENFORCEMENT CRIMINAL ( )COURT ON DUTY
COMPLAINANT
CREDITOR :A….. B….. (T.C.:…………)
ADDRESS
AGENT :Lawyer ………..
ADDRESS
COMPLAINTED
SUSPECT (DEBTOR): C….. D…. (T.C.:………..)
ADDRESS
SUBJECT OF THE REQUEST :
It consists of our request for the punishment of the suspect who issued a dishonoured cheque based on the debt owed to the client and the issuance of a protection order against him.
EXPLANATIONS
Suspect C….. D…. A cheque was drawn by …Bank …Branch of …Bank …Branch with serial number …/../….dated, drawn at …/../…., with a value of TL 000,00, the place of issue of which is …, based on the debt owed to the client. With this cheque subject to the complaint, the client has the title of creditor.
When this cheque was presented to the bank by the client within the time limit, it was seen that TL 000.00 of it was bounced; an annotation was made on the back of the cheque that it was bounced. In order to collect our receivables arising from the cheque in question, which has not been paid, we have initiated proceedings through the file number 2021/….. of Ankara …. Enforcement Directorate The proceedings were initiated through the file numbered 2021/ Esas.
Due to the fact that no payment has been made by the suspect despite the follow-up, we apply to your Court and demand the punishment of the suspect who committed the offence of drawing bad cheques.
LEGAL GROUNDS :
Cheque Law No. 5941 (Article 5 and all other articles), CPL, Law on Attorneys and other relevant legislation
EVIDENCE :
…Bank …Branch’s …serial number …/../….dated cheque (the original cheque is in the safe of the Execution Directorate), Ankara ….Execution Directorate’s 2021/….. E. numbered file subpoena, 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- Suspect C….. who drew a bad cheque D…. to be punished,
2- Suspect C….. D…. be banned from issuing cheques and opening cheque accounts as a protection measure,
3- We request and demand that the trial expenses. Attorney’s fee be decided to be charged to the suspect. 21/09/2021
Bad Cheque Complainant
A…. B…… Acting
Lawyer
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