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Sample Petition For Breach Of Commitment

Sample Petition For Breach Of Commitment

ANTALYA ON DUTY ENFORCEMENT CRIMINAL COURT,

COMPLAINANT : ……………….

AGENT : ………………….

DEFENDANT (DEBTOR) : ………………. (T.C. …………..)

CRIME : BREACH OF COMMITMENT

COMMITMENT DATE : Installments dated …/…./….-…./…/……-…./…./……

SUBJECT OF THE CASE : 3 months imprisonment for the debtor-defendant who violated his commitment

request to be given to the court.

EXPLANATIONS :

We are the attorneys of the creditor………….. in accordance with the attached power of attorney and authorization certificate.

The client bank’s receivable from ……………….. has been initiated with the execution file numbered ANTALYA 9th EXECUTION OFFICE –/– E.

Debtor/defendant ……………. , ANTALYA 9th EXECUTION OFFICE –/– E

., he undertook to pay the entire debt in monthly installments starting from …./…../…../…… However: …/…./…./….-…./…/……-…./…./…./…… dated installments without a justifiable reason. The debtor has breached its commitments. This is evidenced by 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 9th EXECUTION OFFICE –/– E numbered execution file and all kinds of evidence.

CONCLUSION AND REQUEST: As an attorney, we request and demand 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 Authorization Certificate
Minutes of the Letter of Undertaking.

COMPLAINANT’S REPRESENTATIVE

………………..

 

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