TO THE COURT OF COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
SUBJECT : It is about the cancellation of the title deed and our registration request.
CASE VALUE:
(in cases related to assets)
DESCRIPTIONS :
1-) … province, … town, … village/neighborhood, … map section, … island, … plot registered as a field (ANNEX-1), during the cadastral works carried out on …/…/… dated …/…/… , … have been determined on behalf of the defendant/defendant by applying the title deed registration (ANNEX-2). Detection report was finalized on …/ …/ ….
2-) The relevant immovable property is in the possession of our client’s grandfather, first of all, then of his father, and finally of our client, for a period of about … was cut. During all this period, the defendant/defendant and/or his descendants did not have any possession of the immovable property in question.
3-) Inheritance writs (Annex-3) revealing the hereditary relationship between his parent and our client, and examples of documents showing that our client has been authorized by other heirs as a representative to file this lawsuit are attached (Annex-4).
4-) The discovery and expert examination to be carried out by your court at the location of the immovable in question and, if approved by your Court, the statements of witnesses that we will listen to during the hearings (Annex-5) will reveal the situation with all its clarity.
LEGAL REASONS :
LEGAL EVIDENCES: … province, … district, … village/neighborhood, … map, … island, … parcel, land registry records of the immovable with field characteristics, cadastral determination report dated …/…/…, certificates of inheritance, Document showing that the other heirs have been authorized by other heirs as a representative regarding the opening, witness list showing the names and addresses of the witnesses and the subjects they will testify, discovery and expert examination.
CONCLUSION AND CLAIM: For the reasons we tried to explain above, the cancellation of the title deed registration of the immovable subject to the lawsuit, which is still registered in the name of the defendant, and the registration of the said real estate in the name of our client and other heirs represented, (The claim for the value of the lawsuit, “reservation of the rights related to the surplus” or the value of the lawsuit, Whether it is contentious or not may vary according to the petition prepared on the subject of the case, but the relevant requests should be evaluated based on your concrete case.) We request by proxy on behalf of our client to decide that the court costs and litigation expenses be charged to the other party. …/…/…
ATTACHMENTS:
1-) Land registry records of the field-qualified immovable registered in … province, … district, … village/neighborhood, … map, … island, … parcel.
2-) The cadastral determination report dated …/…/….
3-) Certificates of succession.
4-) A document showing that our client has been authorized as a representative by other heirs regarding the filing of this lawsuit.
5-) Witness list showing the names and addresses of the witnesses and the subjects they will testify.
6-) One copy of approved power of attorney.
Plaintiff’s Attorney
Lawyer
