TO FAMILY COURT JUDGE
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : The liquidation of the property regime consists of our request.
CASE VALUE:
(On property rights cases)
DESCRIPTIONS :
1-) My client… …, the defendant … … got married after …/…/… with the Family Court’s decision numbered …/… E, …/… K, dated …/…/…. (ANNEX 1)
2-) While the marriage union was in progress, 8 22 carat bracelets belonging to my client were exchanged on …/…/… and the immovable (ANNEX-2) registered in the … island … parcel was purchased and registered in the name of the defendant … ….
3-) While the marriage union was continuing, 6 22 carat bracelets belonging to my client were exchanged and the defendant ……. The car (Annex-3) with the license plate registered in his name was purchased. It is clear that my client contributed to both the acquisition of the immovable and the purchase of the car by giving his bracelets.
4-) It is in question that my client will receive an increase in value in accordance with Article 227 of the Turkish Civil Code No. 4721 for the contribution he has made to the immovable and automobile purchased in the period when the participation in the acquired property regime is valid, due to his personal property.
5-) Due to present reasons, it has become 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 and automobile belonging to the defendant.
LEGAL REASONS: 4721 S. K. m. 202, 214, 225, 227, 235 4722 S. K. m. 10
LEGAL EVIDENCE:
1-) Divorce decree numbered ../…E., …./… K. of the Court of ….
2-) The title deed registration of the immovable registered in the ….. island …. parcel.
3-) The traffic registration record of the car with the license plate.
4-) Expert examination
5-) Witness list showing the names and addresses of the witnesses and the subjects they will testify
CONCLUSION AND CLAIM: Due to the reasons explained above, the property regime between the defendant and the client during the marriage was liquidated, and the total amount of … TL. On behalf of our client, we respectfully request that the contribution be collected from the defendant together with the legal interest to be carried out from the end of the liquidation, and that the litigation expenses and attorney’s fee be charged to the other party. …/ …/ …
ATTACHMENTS
1-) Divorce decree numbered ../…E., …./… K. of the Court of ….
2-) Title deed registration of the real estate registered in ….. island …. parcel.
3-) Traffic registration record of the car with ….plate.
4-) Expert examination
5-) Witness list showing the names and addresses of the witnesses and the subjects they will testify
6-) One copy of approved power of attorney
Plaintiff’s Attorney
Lawyer
