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 :
CASE VALUE: …….. TL
(In cases related to the subject of the case and property rights)
SUBJECT : …./…./…. The sale of …. The realization of the transfer of the ownership of the plated vehicle on behalf of the plaintiff client consists of the submission of our request.
DESCRIPTIONS :
1-) The vehicle with license plate of …….. and …… brand vehicle by the defendant was sold to the plaintiff client on …/…/… with the sales contract of the …… journal number of the ….. Notary Public.(Annex – 1)
2-) Although the vehicle in question has been sold through a notary public, its ownership has not been transferred to the client yet. (Annex – 2) Due to the fact that the property has not been transferred, the client, as the owner, does not bear any responsibility regarding the vehicle subject to the lawsuit.
3-) Pursuant to Article 20/d of the Highway Traffic Law No. 2918, motor vehicles registered in traffic are required to be sold at a notary public, and the buyer of the vehicle in question does not appear as a client in the registration records, since the traffic registration record of the vehicle sold at the notary public is not changed. Despite the fact that a warning letter (Annex – 3) was issued to the defendant in 2006 to change the traffic record of the vehicle subject to the lawsuit, no response was given to our warning; We tried to reach him in various ways, but all our efforts to reach him were inconclusive. In this regard, the persons whose names are included in the witness list (Annex 4) attached to our petition will give an explanation of the situation, if deemed appropriate by your court.
4-) As it is known, the responsibilities arising from the traffic fines and tax debts of the vehicles that are sold at the notary public but whose traffic registration registration is not carried out belong to the former owner of the vehicle. As a result of this regulation, the client has become obligated to demand the transfer of ownership of the vehicle subject to the lawsuit.
LEGAL REASONS :
LEGAL EVIDENCES: Notary public’s sales contract dated …./…/… with journal number …. License, Notice of …. Notary public with …/ …/ … journal number, Witness statements, oath.
CONCLUSION AND REQUEST: For the reasons explained above, …. Plate …. On behalf of our client, we respectfully request that the ownership of the brand vehicle be transferred to the plaintiff client, that the attorney’s fee and litigation expenses be charged to the other party. …/ …/ …
Plaintiff’s Attorney
Lawyer
