Petition for Removal of Objection and Request for Bankruptcy

TO THE DUTY PRIMARY COMMERCIAL COURT
OF ISTANBUL

PLAINTIFF: Name and Surname-(Turkish Republic Identity Number: …)-Address

ATTORNEY: Lawyer's Name and Surname - Address

DEFENDANT: Name and Surname - Address

SUBJECT: Removal of objection and bankruptcy petition

EXPLANATIONS:

• According to the contract between my client and the defendant, the defendant has still not paid the debt. The notifications sent have been unsuccessful.

2- My client has initiated bankruptcy proceedings against the debtor for the purpose of collecting the debt, and a sample payment order (Example 11) has been sent through the Enforcement and Bankruptcy Directorate under file number …/….

3- The debtor received the payment order and objected within the 7-day legal period. The objection is not legally valid, as we have investigated and learned that the debtor's economic situation is not good.

EVIDENCE: 1- ………. contract, 2- … Enforcement and Bankruptcy Directorate's enforcement file numbered …/…, 3- Expert examination and other legal evidence.

LEGAL GROUNDS: Article 156 of the Enforcement and Bankruptcy Law and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand, as the plaintiff's attorney, that our request be accepted, the objection be dismissed, the defendant be declared bankrupt, and the court costs and attorney's fees be borne by the defendant. …/…/…

Plaintiff's
Attorney's Name and
Surname