Case of Receivables – An Example of a Lawsuit Petition Filed with the Former Manager of an Apartment Building

… JUDGE OF THE MAGISTRATE’S COURT

 

 

prosecutor :

 

TC IDENTIFICATION NUMBER :

address :

attorney :

(Legal representatives of the parties, if any)

address :

(Legal representatives of the parties, if any)

DEFENDANT :

ADDRESS :

SUBJECT : This is our petition, which includes our ability to compensate for the damage suffered by the apartment building during the managerial period.

CASE VALUE :

(In cases related to property rights)

 

descriptions :

1) … Street … Street …/…. located at the address … of the apartment Building …./…/… at the meeting of the floor owners’ board held on October 1, the defendant person was elected as the manager (ANNEX- 1) ….after resigning his post for a year, he resigned, citing that he had disagreements with other floor owners about the style of management in his history. (October- 2)

2) At the condominium owners’ meeting held on the day of /… a month before the date of the defendant’s resignation from the post of manager ………a named person has been appointed as an auditor (October -3); the auditor selected person in the management of the defendant, he is …/… prepared for the period …/…/… dated inspection report (Appendix 4) the defendant with the money that is collected from the floor of the owners to open a bank account where money is held in a personal account, recurring expenses the expenditure committed and undocumented in the book, stationery and telephone exorbitant expenditures, and also to the manager in charge of yourself, even though the fee has not been appointed prior periods appointed between accounts ….-It has been determined that there is a difference of TL lira. An expert review, if deemed appropriate by your court, will also serve to clarify the issue in relation to this situation.

3) the defendant has requested an explanation from him after what he did to the auditor’s report is accepted, but the number registered in Journal of warnings a verbal warning and …noterligi (Annex – 5) apartment-the amount of damage inflicted with legal interest in the case of legal procedure could be done warned that although no payment, no process has been found in.

4) About the defendant …. A complaint has been filed with the Public Prosecutor’s Office and the prosecutor’s office …/…. in the investigation file No. 6, the investigation against the defendant is still ongoing and, together with its legal interest, a total of … October – There has been an obligation to contact your court in order to collect the TL amount from the defendant.

LEGAL REASONS :634 P. K. m. 38, 39, October. m. 1.

LEGAL EVIDENCE : 1. …/…/… minutes of the meeting

…/…/… resignation letter dated
3…./…/… minutes of the meeting

4…./…/… dated audit report

5.….. Notary Public … /…/… dated … numbered notice

6.…/….file your inquiry

7…..Expert

 

CONCLUSION AND CLAIM: The defendant is a manager …/….-we request by proxy that TL, which is the damage suffered by the department during the period, be decided to be collected together with the legal interest that will be processed from the date of the case (may vary depending on the request), court costs and attorney’s fee will be charged to the other party. …/…/…

 

APPENDICES: 1. October 2017 …/…/… minutes of the meeting

2…../…/… resignation letter dated

3…./…/… minutes of the meeting

4…./…/… dated audit report

5.….. Notary Public … /…/… dated … numbered notice

6.…/….file your inquiry

7.An example of a certified power of attorney.

 

 

Deputy Plaintiff

Lawyer.

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