TO FAMILY COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : Liquidation of Goods Regime and Collection of Value Increase Receivable
It Is A Desire.
CASE VALUE:
(On property rights cases)
DESCRIPTIONS :
1-) Our client … …,, got married to the defendant … … on …/…/… and they got divorced with the decision of the Family Court dated …/…/… and numbered …/… E, …/… K. (ANNEX 1)
2-) While the marriage union was continuing, 1 meter of gold chain, 2 bracelets, 1 pair of earrings belonging to our client were exchanged on …/…/… and a land of … square meters registered in the … island … parcel was purchased and registered in the name of the defendant … … in the deed. (ANNEX-2)
3-) While the marriage union is continuing, … TL. The fine works of the single-storey summer house, of which the rough construction was completed by the defendant, were made on the land in question, and the building was made ready for use. (ANNEX-3)
4-) In the article 227 of the Turkish Civil Code No. 4721, “If one of the spouses has contributed to the acquisition, improvement or protection of a property belonging to the other, without any or any appropriate compensation, he has the right to receivable in proportion to his contribution for the increase in value of this property during the liquidation. and this receivable is calculated according to the value of that property at the time of liquidation; In the event of a depreciation, the initial value of the contribution is taken as the basis.” Pursuant to the provision, it is obligatory to file this lawsuit in order to collect from the defendant the contribution made by the client to the liquidation of the property regime and the acquisition and improvement of the immovable property belonging to the defendant.
LEGAL REASONS :
LEGAL EVIDENCE:
1-) … Decision of the Family Court dated …/…/… and numbered …/… E, …/… K
2-) Land Registry dated …/…/…
3-) Bank records dated …/…/…
4-) Expert examination
CONCLUSION AND CLAIM: Due to the reasons explained above, the property regime between the defendant and our client during the marriage was liquidated, and the total amount of … TL. We request, by proxy, on behalf of our client, that the contribution be collected from the defendant together with the legal interest to be carried out as of the end of the liquidation, and that the litigation expenses and attorney’s fee be charged to the other party. …/ …/ …
ATTACHMENTS:
1-) … Decision of the Family Court dated …/…/… and numbered …/… E, …/… K
2-) Land Registry dated …/…/…
3-) Bank records dated …/…/…
4-) One copy of approved power of attorney.
Plaintiff’s Attorney
Lawyer
