… PEACE COURT JUDGE
Prosecutor:
Address:
Attorney:
Address:
DEFENDANT:
ADDRESS:
SUBJECT: Payment of dues and common expense debts and compensation for delays is subject to our claim.
CASH VALUE:
(In cases involving property rights)
INSTRUCTIONS
1) The apartment owners’ association of … Street … Street … met on … /…/… and our client was elected as the manager at this meeting and is performing this duty. (ATTACHMENT- 1) As of the date of the work, the defendant resides in this property as the owner of apartment … (ATTACHMENT- 2)
2) The main property has janitor expenses, and all apartment owners are required to pay monthly dues of … TL for all these expenses. (ATTACHMENT 3) In addition, … TL in common expenses were incurred for the insulation of the roof damaged last winter and the repair of the rain gutters. (ATTACHMENT 4)
3) Article 42 of the main property’s management plan clearly defines the share ratios of the apartment owners participating in the common expenses, and the first paragraph of the article stipulates that the common expenses shall be shared equally among the owners of the eight normal floors and two attic floors in the main property. (ATTACHMENT 5)
4) In cases involving the defendant, at the property owners’ meeting on …/…/…, all property owners agreed that the defendant should perform an unrelated task, namely the expenses for the janitor, baker, gardener, and caretaker, and the total amount – TL – TL to be paid for roof maintenance and repair. (ATTACHMENT – 6)
5)
The defendant apartment will pay …… TL …. as a maintenance fee for the remainder of the year and month for the duration of its life. For the months of ……, ……, and ……, a total of …… TL in common expenses, such as roof repairs, must be paid, which is the unpaid expense of TL …… – TL. The expense of TL is not included in the expenses. In the October Appendix, the relevant persons whose names appear in the witness list (October 7) submitted with our petition regarding this matter will make statements about the situation if deemed appropriate by your court, and the expert and research investigations to be conducted will also clarify the matter.
6) Despite the defendant being warned in the notification dated …/…/… and numbered … (ATTACHMENT – 8) that they must also pay their debt, no payment has been made to date.
7) For the fees and common expenses – … TL and … /…/… amount of payment delays, the obligation to pay the amount owed for the days of delay in payment from the date of the meeting of the condominium owners’ association on … – TL delay compensation and the total amount of … has arisen, and the obligation to contact your court to collect this amount from the defendant has arisen.
LEGAL GROUNDS: 634 PK m. 20, October 22, Annex m. 1; 6100 s. K. m. 4, 12
Legal evidence: Minutes of the meeting dated …/…/…, sample of the title deed, dated …/…/…, …/…/…, and …/…/…, janitor, payroll dated …/…/… 5 copies and dated …/…/… dated 4 invoices …/…/… dated main real estate management plan sample …/…/… dated meeting minutes, ….. Notary … /…/… dated … numbered notification
CONCLUSION AND SUMMARY
The condominium owners’ association is obligated to pay the dues and common expenses in the amount of TL for the days of delay in payment starting from the meeting dated ….. I request, on behalf of my client, that the other party be charged the late payment penalty in the amount of TL and the total expenses in the amount of …, and that the court costs and attorney’s fees also be charged to the other party. …/…/…
ECLAIR:
Minutes of the meeting dated …/…/…
Copy of the land registry
Caretaker payroll slips dated …/…/…, …/…/…, and …/…/…
5 invoices dated …/…/… and 4 invoices dated …/…/…
Copy of the management plan for the main property dated …/…/…
Minutes of the meeting dated …/…/….
Shows the names, addresses, and subjects to be testified by the witnesses. Witness list,
….. Notary Public …/…/… dated … numbered notification.
Sample of the certified power of attorney.
Plaintiff’s Attorney