……. TO THE HONOURABLE JUDGE
DEFENDANTS :…….
DEFENDANT :…….
SUBJECT : Our Request for Compensation of ………-TL from the defendant. Who damaged the Common Ground.
EXPLANATIONS : My clients are located at ……. and ……. Province, ……. District, ……. Neighbourhood, ……. plot, ……. island, ……. parcel, …. numbered independent. Sections on the main immovable registered to the title deed. The defendant is the owner of the independent section numbered … in the same immovable.
The defendant demolished ………, which is a common area, on …/…/…. without the permission of the other. Floor owners and without any justifiable reason. Damage incurred for this reason is ………..-TL.
The verbal warnings made to the defendant to compensate the defendant for the damages. He caused were inconclusive, and upon this, a notice dated …/../…. and dated ….. was issued to him by ……… Notary Public. Despite this notice, the defendant did not indemnify the damage.
For these reasons, it has become necessary. To file this lawsuit for the compensation of ……….-TL.
CAUSES : Condominium Law and Related Legislation
EVIDENCE :Land Registry, Notice, Discovery and Expert Examination
CONCLUSION OF THE REQUEST : For the reasons stated above, we respectfully request and demand. That the defendant be ordered to collect this money from the plaintiff, who caused ………..-TL damage by demolishing ……… from the common places. Together with interest from the date …/…/…., to charge the defendant with the costs of the proceedings, and to award. The counterparty attorney fee on our behalf as an attorney in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667. …….
PLAINTIFFS’ COUNSEL
…….
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