TO THE JUDICIARY OF 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: 1-) Treasury
2-) Forestry Administration
SUBJECT : It consists of our registration request for immovable without title deed.
CASE VALUE:
(in cases related to assets)
DESCRIPTIONS :
1-) The immovable subject of the lawsuit, which is a field adjacent to the parcels in the village of … and …, is not registered in the title deed. The immovable subject of the lawsuit is outside the forest cadastre made in … and the application of article 2/B, and is in places that do not have forest qualifications (ANNEX-1).
2-) The relevant immovable was sold to our client by … … with the external sales contract (Annex-2) dated …/…/… and its possession was transferred.
3-) Our client has been an active possession of the said place during the intervening year and has benefited from the immovable by cultivating it. This situation will be clarified by the discovery and expert examination to be carried out by your court at the location of the immovable, and the statements of witnesses (Annex-3).
4-) Since the conditions for acquiring immovable by means of gainful statute of limitations on behalf of our client due to the reasons explained above, it has become necessary to apply to your court for the registration of the immovable subject to the lawsuit.
LEGAL REASONS :
LEGAL EVIDENCE: External sales contract dated …/…/…, forest cadastral maps, witness statements, discovery and expert examination regarding the immovable subject of the lawsuit in the village of … and … adjacent to the parcels.
CONCLUSION AND REQUEST: For the reasons explained above, the decision to register the immovable property subject to the lawsuit in the title deed on behalf of our client, (The request for the value of the lawsuit, the “reservation of the rights regarding the surplus” or whether the lawsuit value is in contention may vary according to the petition prepared on the subject of the lawsuit, Relevant requests should be evaluated on the basis of your concrete case.) We request, by proxy, that it be decided to charge the litigation expenses and attorney’s fee to the other party. …/…/…
ADDITIONAL:
1-) Forest cadastral maps.
2-) External sales contract dated …/…/… regarding the immovable which is the subject of the lawsuit in the village of …, adjacent to the … and … parcels.
3-) Witness list showing the names and addresses of the witnesses and the subjects they will testify.
4-) One copy of approved power of attorney.
Plaintiff’s Attorney
Lawyer
