Compensation Against A Condominium Owner Causing Damage To Common Areas
TO THE HONORABLE COURT
PLAINTIFFS: …….
THEIR ATTORNEYS: …….
DEFENDANT: …….
SUBJECT: Our Claim for Compensation of ……… TL from the Defendant for Damages to Common Property.
EXPLANATIONS: My clients are the owners of independent units numbered … located on the immovable property registered in the land registry at ……. address, ……. Province, ……. District, ……. Neighborhood, ……. sheet, ……. block, ……. parcel. The defendant is the owner of independent unit numbered … on the same immovable property.
On ../../…, the defendant demolished ………, which was a common area, without the permission of the other unit owners and without any valid reason. The resulting damage amounts to ……….. TL.
Verbal warnings were issued to the defendant to pay compensation, but these were unsuccessful, and a formal notice dated ../../…. and numbered ….. was issued by the ……… Notary Public. Despite this formal notice, the defendant has not compensated for the damage caused.
For these reasons, it has become necessary to file this lawsuit to recover ……….-TL.
REASONS: Condominium Law and Related Legislation
EVIDENCE: Title Deed, Warning Letter, Discovery and Expert Examination
CONCLUSION: For the reasons stated, the defendant demolished ……… from the common areas, causing ………..-TL in damages to the plaintiff. The plaintiff requests that this amount be collected with interest from ../../…. , the imposition of litigation costs on the defendant, and the award of attorney’s fees to us as attorneys, in accordance with the last paragraph of Article 164 of the Attorney Act No. 1136, as amended by Act No. 4667. …….
PLAINTIFFS’ ATTORNEY