26 Nov REQUEST FOR CANCELLATION OF THE CONSTRUCTION CONTRACT IN EXCHANGE FOR THE APARTMENT
TO THE … 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 : …/…/… Request for Cancellation of the Construction Contract for the Floor Dated.
INSTRUCTIONS :
1-) Our client, defendant … Construction LTD. on the date of … /…/… He signed the Construction Contract for the Floor. (ANNEX-1) In accordance with this agreement, the defendant will build a 5-storey apartment building on an m2 plot of land at the address … Ada, … registered with the parcel number … in the Title Deed belonging to our client, and our client will be decked and 1. I’ll give you the apartments on the floor. (APPENDIX-2)
2-) According to the contract concluded, the defendant will deliver the apartments to our client on /…/… date. But despite the fact that a month has passed since the defendant’s delivery date, he has not completed the construction and has not delivered the mentioned apartments to our client.
3-) Therefore, it has become mandatory to file a lawsuit for the cancellation of the said contract.
LEGAL REASONS : 6098 P. K. m. 470, 473
LEGAL EVIDENCE :
1-) Land registry records,
2-) …/…/… Construction Contract for Apartment Provision
3-) Exploration,
4-) Expert review.
CONCLUSION AND REQUEST: For the reasons described above, I respectfully request from your Supreme Court that the defendant be decided on the cancellation of the contract concluded on the date of /…// with the defendant, the imposition of the costs of the trial on the defendant. …/…/…
Plaintiff’s Attorney
ADDITION:
1-) Construction Contract for the Floor dated …/… /…
2-) Land registry records,
3-) An example of a certified power of attorney.
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