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.