COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Compensation (…… TL)
FACTS : 1- With the materials belonging to the plaintiff client, the defendant has built a construction on his own immovable property registered in …., …… parcel number of the title deed.
2- During this construction, the defendant acted in bad faith, although he knew that the materials belonged to the plaintiff and were necessary.
3- The names and prices of the materials used are presented in the attached list and their total value is …… TL.
4- Since it is not technically possible to dismantle the construction and return the materials, it is necessary to demand compensation instead of return.
For this reason, it has become compulsory to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Material price list, witness, discovery etc. evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above. I request that the lawsuit. Be accepted and the total amount of …… TL be taken from the defendant and given to the plaintiff. That our right to demand more is reserved, and that the costs and attorney. Fees be imposed on the defendant.
I would like to request. Sincerely yours,
Plaintiff’s Counsel
ATTORNEY………………….
(SIGNATURE)
ANNEX:
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