-SAMPLE PETITION-
ANKARA SENTRY MAGISTRATE’S COURT
REQUESTING DAMAGE DETECTION
PROSECUTOR :
ADDRESS
ATTORNEY :
ADDRESS
DEFENDANT :
ADDRESS
SUBJECT OF CLAIM: It is about the request to determine the damages and deficiencies caused by the evacuation of the leased real estate on the basis of the compensation case to be opened.
INSTRUCTIONS
Ownership of the plaintiff client A….. B….. at work, which belongs to , ../../…. the defendant, who is present as a tenant with the initial lease agreement (OCTOBER-1), C….. E…., due to non-payment of the last … monthly rent, AnkaraExecutive Directorate ‘s 2021/….. He started the follow-up with his main Numbered file (OCTOBER-2). With the finalization of the proceedings by us, the Executive Civil Court of Ankara ( ) 2021 /…. It was requested that the defendant be decided to be evicted due to default with the case file numbered as (OCTOBER-3). After the acceptance of our request, the defendant is from the residence subject to the request../../…. the building has been evacuated.
After the defendant’s eviction took place, it was seen that there was some damage to the residence by the client. It is impossible for the client to accept housing in this way. It is possible that he will neither use nor rent the house in question in this damaged state. The defendant unlawfully damaged the client’s real estate; he caused damage to the client. For this reason, it has become our responsibility to file a lawsuit against the defendant for the damage and loss he caused to the property.
For the reasons described above, we will file a damage and loss lawsuit against the defendant, as well as there is a need to repair the existing damage;
Determination of damages and deficiencies that have occurred,
Calculation of the necessary materials and labor costs for the elimination of these damages and deficiencies,
To determine the time that will elapse for the elimination of damage and the loss of earnings that the client will experience during this process, and
We request your Court to determine the depreciation of the immovable property.
LEGAL REASONS : Law No. 6570, IIK (156 and all other articles), HMK, Av. Law and other relevant legislation
EVIDENCE : Ankara ….Executive Directorate ‘s 2021/….. E. Subpoena of file No. 2021 of the Executive Criminal Court of Ankara ( ) /…. The main numbered file is the subpoena, ../../…. Initial Lease Agreement, Expert report, Discovery, Witness statements (If Deemed Necessary), Other kinds of delail
CONCLUSION AND CLAIM: For all the reasons described above and which will be considered by your court you’re,
1-Acceptance of our case and determination of the issues listed above,
2- We offer and request that the determination costs, trial costs and the power of attorney be decided to be left on the counterparty. 06/10/2021
Requesting Damage Determination
A…. B…… Acting
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