Request for Collection of Debris Removal Costs and Tree Planting Costs

TO THE DUTY PRIMARY CIVIL COURT

ANKARA

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

ATTORNEY:
Lawyer's Name and Surname,
Address

DEFENDANTS:
Name and Surname
Address
Name and Surname
Address

SUBJECT:
This is a request for a court decision ordering the defendants to jointly and severally pay ... TL for demolition costs and ... TL for tree planting costs, along with legal interest from the date of this lawsuit, for the structure built by my client on the property located in ... District, ... Neighborhood, ... Island, ... Parcel, in ... Province, owned by the defendants, reserving our rights to claim further amounts.

VALUE OF THE CLAIM:
… TL (Subject to our rights regarding any excess amount)

EXPLANATIONS:

1. The plaintiff client has resided for many years in ... Province, ... District, ... Neighborhood, ... block, ... parcel, and has constructed the buildings on this property using his own resources. My client has regularly paid all taxes related to the buildings he constructed on the property. Receipts for paid Environmental Cleaning Tax and Building Tax are submitted as an annex to the petition (ANNEX 1).
2. The defendants acquired the property through a sale via file number …/… of the … Enforcement Directorate and only possess the bare ownership of the land. However, the defendants' claim to the structures belonging to my client on the land is unlawful.
3. The compensation my client is requesting for demolition and tree planting is for structures he built and trees he planted on the land using his own resources. The fact that the defendants acquired ownership of the land without making any payment for these structures creates an unfair situation.
4. The defendants should understand that simply owning the land does not grant them rights to these structures. This lawsuit has been filed to recover the expenses incurred by my client and to remedy the resulting harm.

LEGAL GROUNDS:
Turkish Code of Obligations, Turkish Civil Code, and other relevant legislation.

EVIDENCE:

1. ...Receipts for Building Tax and Environmental Cleaning Tax paid to the Municipality,
2. Land registry records,
3. … Enforcement Directorate’s file number …/…
4. ... Civil Court of First Instance, case file number .../..
5. Witness statements, expert reports, and other legal evidence.

WITNESSES:

1. Name and Surname (Turkish Republic Identity Number: …)
   Address
2. Name and Surname (Turkish Republic Identity Number: …)
   Address

CONCLUSION AND REQUEST:
For the reasons explained above;

1. We hereby request that the defendants be held jointly and severally liable for … TL demolition costs and … TL tree planting costs, reserving our rights to claim further amounts for the structure belonging to our client
2. Legal interest shall be applied to the requested amounts from the date of the lawsuit
3. I respectfully request and demand that the court order the defendants to pay the court costs and attorney's fees jointly and severally.

…/…/…

Plaintiff's
Attorney's Name and
Surname