Petition for Assessment of Damage to Leased Property

TO THE DUTY CIVIL COURT OF PEACE,
ANKARA

REQUEST FOR EVIDENCE COLLECTION BY: [Name and Surname Confidential] (Turkish ID No: …) – [Address Confidential]

REPRESENTATIVE: [Lawyer's Name and Surname Confidential] – [Address Confidential]

OTHER PARTY: [Apartment Name Hidden] Apartment Management

SUBJECT: This request concerns the determination of the damage to my client's apartment, the circumstances causing the damage, and the amount of expenses required for compensation.

EXPLANATIONS:

1. My client owns an apartment (ground floor) located at [Address Hidden] and due to water seeping into the ground from the surrounding area and water accumulation in the boiler room, the parquet flooring in the apartment has swollen, the plaster on the walls has peeled and flaked, and there is also a foul odor inside the apartment due to the dampness.
2. My client had the damage to the parquet flooring in their apartment repaired at their own expense (Amount Confidential), but when they requested reimbursement for these repair costs from the apartment management, they received a negative response.
3. My client has repeatedly contacted the building management, both verbally and in writing, regarding the damage to their apartment and the deficiencies that caused it. However, due to the negative responses from the building management, it has become necessary to file this request for assessment on behalf of my client.
4. My client applied to the [Municipality Name Withheld] Municipality Department of Public Works to have the damage and unsanitary conditions in their apartment assessed. The [Municipality Name Withheld] Municipality Department of Health Affairs conducted an on-site inspection and prepared a Sanitary Assessment Report dated [Date Withheld], confirming my client's grievance and justification for their complaint.
5. For the reasons stated above, we request that the following matters be determined by expert witnesses before your court:
   • A detailed list of all damages and losses incurred in my client's apartment,
   • Identifying the factors that caused the damage and losses in my client's apartment
   • Determining the amount of expenses required to repair the damage and losses incurred in my client's apartment.
6. While reserving all our material and moral claims, it has become necessary to file this lawsuit in your court to determine the matters mentioned above.

EVIDENCE:

1. Photocopies of written applications submitted to the apartment management on various dates
2. Photocopies of the response letters containing the negative answers given by the apartment management,
3. Report dated [Date Hidden] from the Health Affairs Directorate of [Municipality Name Hidden] Municipality,
4. Expert examination,
5. Witnesses and all kinds of legal evidence.

LEGAL GROUNDS: Turkish Code of Obligations and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand that a decision be made to determine the extent of the damage to the apartment at [Address Hidden], the causes of the damage, and the amount of expenses required to repair the damage.
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Attorney Requesting Evidence Gathering
[Attorney's Name and Surname Confidential]
Signature