To Antalya Civil Court of Peace ( )
The action is demanding.
Requesting
Heirs: Name Surname TR Address
Deputy : Atty………..
Other Heirs: Name Surname TR Address
Name Surname TR Address
Subject of Litigation: It consists of our requests to determine the estate belonging to the inheritor, to appoint a representative to this estate and to take measures.
Descriptions
The clients A….. B….. and D….. B….. who request the determination of the estate from your Court with this petition, are siblings and their fathers are deceased C….B…. (Identity information of the deceased is attached to the petition Annex-1), ../../…. He died on his date. As it can be understood from the certificate of inheritance (Annex-2) that we have submitted in the appendix to the petition, the two other persons other than the applicants and the clients are the heirs of the testator.
There is no known will left by the testator. Although some of the assets of the deceased are known to us, we submit our requests to your Court as follows so that the unknown part can be determined.
The assets of the testator known to the clients (Annex-3) are as follows:
one-
2-
We request the following to be determined in order to determine the assets of the deceased that are unknown to the clients:
1-Determining the account records and account movements, vehicle and bank deposits, assets and liabilities held jointly or individually by querying the bank account records of the depositor
2-Determining the progress payments of the deceased from official institutions with the writ to be written to the SGK
3- Identification of the assets and liabilities of the deed records, including the transfer transactions, by questioning through TAKBİS
4-Determining the tax records of the deceased by writing a writ to the Revenue Administration
5-We demand that the assets and liabilities of the motor vehicles belonging to the Muris be determined by questioning.
Since there is an inherited enmity between the plaintiff clients and the other two legal heirs of the testator; It is thought that with the emergence of the estate to be determined by your Court in addition to the existing estate, situations that will create loss of rights for the clients may arise. For this reason, in order to prevent the heirs from losing their rights and to protect the integrity of the estate, we request your Court to appoint a representative to the estate in question, since it is necessary to take measures on the estate that is already known and to be determined by your Court, and to keep a book in order not to damage the determined matters.
Legal reasons :
Evidence: Murise population registration information, certificate of inheritance, title deed records, expert report, all other evidence.
Conclusion and Request: For all the reasons explained above and which will be taken into account by your Court ex officio:
First of all, we accept our case, which includes our demands listed above,
Appointment of a representative to the already known estate to be determined by your Court,
In this direction, writs were written to the above-mentioned relevant authorities to determine the assets of the testator in the estate.
In order to prevent the heirs from losing their rights and to protect the integrity of the estate, measures should be taken on the already known estate to be determined by your Court,
By proxy, we supply and demand that the litigation expenses and attorney’s fees be charged to the other side. 08/12/2021
Attorney of Claimants
Lawyer…….
