TO Mr. JUDICIARY
MEASURE IS DEMANDED
…….
CLAIMERS:…….
ATTORNEY: …….
DEFENDANT:…….
SUBJECT: Deed Cancellation and registration
VALUE : …….
EXPLANATIONS :1-Our clients are the children of a family of 6 siblings. Among our clients, who lost their father a long time ago, Ayşe had to take care of her old and sick mother at home, as she was the youngest. The woman, who suffered from diabetes, high blood pressure and memory loss for many years, died 3 months ago at the age of 96. (certificate of inheritance is attached)
2- Ali, the eldest of the brothers, is unemployed and has bad habits. During his father’s health, all opportunities were given to him, he was given flats and shops while he was getting married, but he divorced in a very short time, and the properties built on him were consumed in the realm of pleasure.
3- After his father died, he often took cash from his old mother on the pretext of starting a new business and spent it in gambling.
4-Finally, our clients ……. Bay, ……. location, Layout:……., Plot: ……. We have learned that he sold the ….. m2 immovable property located in Istanbul to the father of his wife, whom he later married, with a private sales power of attorney, which he obtained from his 96-year-old mother, in an unknown way, for a price of ……….-TL. Mothers of our clients
5- The purpose of ………… is purely for personal benefit, and he will live his day by converting this property, which he later smuggled from other heirs, into money.
6- The buyer of the real estate ………… has no income and is also taken care of by our client’s elder brother (son-in-law).
7-For this reason, we request the cancellation of this fake sale transaction and its registration in the name of the heirs again. Again, in order to prevent the malicious defendant from selling the real estate to third parties, we request that measures be taken to prevent the sale of the real estate whose plot and parcel is mentioned above.
LEGAL REASONS: UK AND RELATED LAW ARTICLES
EVIDENCE: Land Registry, Certificate of Inheritance, Witnesses, all kinds of evidence.
ANSWER TIME: 10 days
RESULT OF THE CLAIM: For the reasons explained above, in order to prevent the malicious defendant from selling the real estate to third parties, measures should be taken in order to prevent the sale of the real estate whose plot and parcel are mentioned above, it was decided to cancel the registration of the real estate in the name of the defendant, the costs of the trial were charged to the other party, the Law No. 1136 of Attorneyship 4667 In accordance with paragraph 164/last amended by Law No., we request that the other party attorney’s fee be decided on our behalf as an Attorney.
ATTORNEY’S ATTORNEY
