TO THE COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : …/…/… Request for Cancellation of the Construction Contract for Flat for Flat.
DESCRIPTIONS :
1-) Our client, the defendant … İnşaat LTD. signed the Construction Agreement for Flats on …/…/…. (ANNEX-1) Pursuant to this contract, the defendant will build a 5-storey apartment building on a land of …m² at the address of …, registered with the parcel number of … Island, … in the Land Registry belonging to our client, and will give our client the apartments on the ground floor and the first floor. (ANNEX-2)
2-) According to the contract made, the defendant will deliver the flats to our client on …/…/…. However, the defendant has not completed the construction and has not handed over the aforementioned apartments to our client, even though … months have passed since the delivery date.
3-) For this reason, it has become mandatory to file a lawsuit for the cancellation of the said contract.
LEGAL REASONS :
LEGAL EVIDENCE:
1-) Land registry records,
2-) Construction Contract in return for Flat dated …/…/…
3-) Discovery,
4-) Expert examination.
CONCLUSION AND CLAIM: For the reasons we have explained above, I respectfully request from the Supreme Court to cancel the contract signed with the defendant on …/…/… …/…/…
Plaintiff’s Attorney
Lawyer
ATTACHMENTS:
1-) Construction Contract in return for Flat dated …/…/…
2-) Land registry records,
3-) One copy of approved power of attorney.
