Request for Delivery of Site Management Documents

TO THE DUTY CIVIL COURT OF PEACE,
ANKARA

PLAINTIFF:
Name and Surname – (Turkish Republic Identity Number: …) – Address

ATTORNEY:
Lawyer's Name and Surname – Address, Telephone Number

DEFENDANT:
Name and Surname – Address

SUBJECT:
Request for delivery of site management ledgers and documents.

EXPLANATIONS:

1- My client has been appointed as the newly elected manager of the … Site, and the term of office of the former manager, the defendant, ended on …/…/…. Although the defendant, whose term of office had expired, was required to deliver the site's income and expense ledgers, receipts, activity reports, and all other documents related to the site's management, he failed to do so.

2- In accordance with decision number … taken at the extraordinary board meeting held on …/…/…, the defendant was given seven days to deliver all documents to the new management. However, despite this period having passed, the defendant has not delivered the said documents, and this situation has put the site management and all apartment owners in a difficult position.

3- The site management lacks any information regarding important matters such as financial status, dues payments, and expenses. The new management is unable to function properly because the previous manager has not submitted the necessary documents. This situation is causing unrest among residents, and the submission of the required documents is essential for resolving these issues.

4- Due to the defendant, the former manager, persistently refusing to hand over the documents, it has become necessary to demand their delivery through legal means.

EVIDENCE:
1- Site management minutes book
2- Witness statements
3- Other relevant legal evidence

LEGAL GROUNDS:
The Condominium Law, the Code of Civil Procedure, and other relevant legislation.

CONCLUSION AND REQUEST:
For the reasons explained above, we respectfully request and demand that:
1- The defendant, the former manager, be ordered to hand over the site's management ledgers, receipts, and all documents to the new management;
2- The court costs and attorney's fees be borne by the defendant.

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