TO THE COURT OF FIRST INSTANCE JUDGE
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : It is our desire to prevent confiscation of the immovable on which a transformer is built by confiscating without expropriation.
CASE VALUE:
(On property rights cases)
DESCRIPTIONS :
1-) …… location, ……………..… island ….. parcel no. … is registered in the name of our client. (ANNEX 1)
2-) On …/…/….., the defendant intervened in the real estate by constructing a transformer on the real estate by confiscating it without expropriation without a just and valid reason.
3-) Since there is an interference with a part of the real estate in question, our client has not been able to use or dispose of the rest of the real estate.
4-) Our client sent the notice of ….. Journal no. ….. dated …./…./….. of the Notary Public (Annex-2) to the defendant to restore the immovable property to its former state. However, the defendant did not heed the warnings in question.
5) It has become obligatory to apply to your Court in order to prevent the seizure of our client’s real estate and to restore it.
LEGAL REASONS :
LEGAL EVIDENCE:
Land Registry
Notice of …….. Notary Public dated …./…./….. journal no. …..
Expert
4. Discovery
CONCLUSION AND REQUEST: Due to the reasons explained above, we respectfully request, on behalf of our client, that it be decided to prevent the seizure of our client’s immovable and restore it to its former state, and to charge the other party with the attorney’s fee and litigation expenses. …/ …/ …
APPENDIX: 1. Land Registry
Notice of …….. Notary Public dated …./…./….. journal no. …..
One copy of certified power of attorney.
Plaintiff’s Attorney
Lawyer
