Request For Refund Of Construction Materials Used In The Work Contract
COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT OF LAWSUIT : Compensation (…… TL)
FACTS : 1- With the materials belonging to the plaintiff client, the defendant built a construction on his own immovable property registered on …., …… parcel number of the title deed.
2- While building 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 mandatory to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Material price list, witnesses, 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 claim more is reserved, and that the costs and attorney fees be imposed on the defendant.
I would like to submit my request. Sincerely yours,
Counsel for the Plaintiff
Atty………………….
(SIGNATURE)
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