Lawsuit Against Condominium Owners Who Fail To Pay Their Debts
TO THE HONORABLE COURT
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Our Request for Collection of …….
EXPLANATIONS: My client and the defendant are the co-owners and shareholders of the real estate located at ……. address and registered in the land registry of ……. Province, ……. District, ……. Neighborhood, ……. Block, ……. Sheet, ……. Parcel.
Pursuant to the contract dated ../../…. the defendant has not paid the amount of ………..-TL required for the construction to begin, and the notice of default issued by the …… Notary Public on ../../…. with serial number …… has also been unsuccessful.
The defendant’s attitude has put my client and other co-owners in a difficult position. As a result of the defendant’s failure to fulfill his obligation, construction cannot begin, and construction costs are increasing every day, causing damage to my client.
It has become necessary to file this lawsuit to collect …………-TL from the defendant who violated the contract.
REASONS: Condominium Law and Related Legislation
EVIDENCE: Title deed, Contract, Notice of Default
CONCLUSION: For the reasons stated above, the defendant is obligated to pay ………-TL from ../../…. , along with legal interest from that date, the imposition of litigation costs on the defendant, and the award of attorney’s fees to us as attorneys in accordance with the final paragraph of Article 164 of the Attorney Act No. 1136, as amended by Act No. 4667. …….
PLAINTIFF’S ATTORNEY
