Compensation Against The Landlord For Damage To The Common Area
TO THE HONORABLE JUDGE
THE PLAINTIFFS :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : Our Request for Compensation of ………-TL from the defendant who damaged the Common Ground.
EXPLANATIONS : My clients are the owners of a property located at ……. and located in ……. Province, ……. District, ……. Neighborhood, ……. plot, ……. island, ……. parcel, …. numbered independent sections on the main real estate 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. Therefore, the damage incurred is ………..-TL.
The verbal warnings made to the defendant to compensate for the damages he caused were inconclusive, whereupon a notice dated ../../…. and numbered ….. was issued to him from ……… Notary Public. Despite this notice, the defendant did not indemnify the damage caused.
For these reasons, it has become necessary to file this lawsuit for the compensation of ……….-TL.
REASONS : 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 a lawyer in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667. …….
PLAINTIFFS' COUNSEL