TO THE COURT OF FIRST INSTANCE
PRECAUTIONARY CAUTION IS DEMANDED
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 : It consists of the request for the return of the immovable due to the loss.
DESCRIPTIONS :
1-) The client sold the immovable (ANNEX-1) registered on the title deed, located at the address … island, … parcel to the defendant … … for …-TL on …/…/…. (ANNEX-2)
2-) At the time of the sale, my client has just come from the military and is in financial difficulty due to marriage preparations. This matter will be clarified by the statements of our witnesses, whose names and addresses are written in the witness list (Annex-3), if your court deems it appropriate. In addition, my client is inexperienced in terms of age and does not have information about the real value of the real estate.
3-) The defendant, taking advantage of my client’s inexperience and urgent need, purchased the immovable at the aforementioned price.
4-) The real value of the immovable is much higher than this price and we have to file this lawsuit in order to ensure the return of the immovable sold under the conditions of gain.
–
LEGAL REASONS : –
LEGAL EVIDENCES : 1-) Immovable Land Registry Record
2-) Contract of sale dated …/…/…
– 3-) The witness list showing the names and addresses of the witnesses and the subjects they will testify,
4-) Expert
5-) Discovery
CONCLUSION AND REQUEST: We respectfully request, on behalf of our client, that, for the reasons we have set out above, first of all, in order to prevent the transfer of the immovable, it is decided to put an annotation of disclaimer in the land registry, to cancel the title deed registration of the immovable and to be registered in the name of the client, and to charge the litigation expenses and attorney’s fee to the other party. …/ …/ …
ATTACHMENTS:
Immovable Land Registry Registration
Contract of sale dated …/…/…
Witness list showing the names and addresses of the witnesses and the subjects they will testify
One copy of certified power of attorney.
Plaintiff’s Attorney
Lawyer
