……. TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our Request for Collection of ……..
EXPLANATIONS :
My client and the defendant ……. located at the address ……. Province, ……. District, ……. Neighbourhood, ……. ……., ……., ……., ……. parcel, ……., located at ……. address and registered to the title deed.
Pursuant to the contract dated …/../…., the defendant has not paid ………..-TL, which is required to be paid in order for the construction to start, until today, and the notice of …… Notary Public dated …/../…. and numbered …… has not yielded any results.
This behaviour of the defendant has left my client and other condominium owners in a difficult situation. As a result of the defendant’s failure to fulfil its obligations. The construction cannot be started and the construction costs are increasing day by day and causing losses to my client.
It has become necessary to file this lawsuit for the collection of …………-TL from the defendant who violated the contract.
CAUSES : Condominium Law and Related Legislation
EVIDENCE : Land registry, Contract, Notice
CONCLUSION OF THE REQUEST : For the reasons stated above, we respectfully request and demand that the defendant be ordered to collect ………-TL, which the defendant is obliged to pay, from the defendant together with legal interest from the date of …/…/…., 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. …….
ATTORNEY FOR THE PLAINTIFF
…….
You can access our other article examples and petition examples by clicking here.