TO THE JUDICIARY OF THE COURT;
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
(On property rights cases)
SUBJECT : The allocation of the immovable consists of our request.
DESCRIPTIONS :
1-) The defendant, who is one of the shareholders of the parcel numbered ….. ….. …. , to our client …. m2 section was sold externally and our client also built a house by structuring in this section. (ANNEX 1)
2-) As a result of the lawsuit filed by our plaintiff client against the defendant, with the court decision of the ….Court numbered …/… E. …./… K. …. Parcel numbered …. It has been decided to register the m2 part in the name of our client. (ANNEX-2)
3-) As such, the part indicated by … in the sketch, …. It is necessary to allocate from the parcel no., as a matter of fact …. In the letter dated …/…/… sent from the municipality, it was stated that it is possible to allocate it. (ANNEX-3)
4-) We are obliged to file this lawsuit for the allocation of the specified part of the immovable.
LEGAL REASONS: 4721 S. K. m. 705, 3194 S. K. m. 15, 16
LEGAL EVIDENCE:
1-) Real estate title deed records
2-) Court decision of the ….Court numbered …/… E. …./… K.
3-) Letter from the Municipality dated …/…/…
4-) Expert
5-) Discovery
CONCLUSION AND REQUEST: For the reasons we set out above, we respectfully request on behalf of our client that the immovable be allocated and registered in the name of the client, and that the litigation expenses and attorney’s fee be charged to the other party. …/ …/ …
ATTACHMENTS:
1-) Real estate title deed records
2-) Court decision of the ….Court numbered …/… E. …./… K.
3-) Letter from the Municipality dated …/…/…
4-) One copy of approved power of attorney
Plaintiff’s Attorney
Lawyer
