Petition for Collection of Joint Renovation and Repair Expenses

TO THE DUTY CIVIL COURT OF PEACE

PLAINTIFF:
Authorized Person on Behalf of Site Management (Name and Surname)
Address: …

ATTORNEY:
Lawyer's Name and Surname
Address: …

DEFENDANT:
Name and Surname
Address: …

SUBJECT OF THE LAWSUIT:
The lawsuit seeks a court order to pay the defendant for the common renovation and repair costs attributable to their independent unit.

VALUE OF THE CLAIM:
… TL

EXPLANATIONS:

1. The defendant is the owner of apartment number … in the … Apartment building located in … district, … neighborhood, … block, … parcel in … province.
2. Due to damage in the common areas of the apartment building (stairs, elevator, roof and exterior facade), mandatory renovations and maintenance were carried out. The total cost of these renovations was shared among all apartment owners. The defendant's share of these works is … TL.
3. The defendant was notified in writing regarding their share of the costs and given additional time to pay. Furthermore, the debt information was posted on the apartment building's notice board. However, the defendant has not paid their share and has failed to fulfill their obligation.
4. According to Article 20 of the Condominium Law, condominium owners have an obligation to contribute to the maintenance and repair costs of common areas. The defendant's failure to fulfill this obligation disrupts the financial balance of the apartment management and causes hardship to other condominium owners.
5. For these reasons, it has become necessary to file this lawsuit to collect the defendant's unpaid share of costs, together with legal interest.

EVIDENCE:

1. Land registry record
2. Apartment management plan
3. Renovation and repair bills
4. Warning notices and official notices
5. Expert report
6. Other legal evidence

LEGAL GROUNDS:
Article 20 of the Condominium Ownership Law and related legislation.

CONCLUSION AND REQUEST:
For the reasons explained above:

1. The case is accepted,
2. The court orders the defendant to pay the common renovation and repair costs amounting to … TL, corresponding to their independent unit, together with legal interest
3. The court costs and attorney's fees shall be borne by the defendant

I respectfully request and demand a decision on behalf of my client.

…/…/…
Plaintiff's
Attorney Name and Surname
Signature