TO THE COURT OF FIRST INSTANCE
Plaintiff: A….. B….. (T.C.:………..)
ADDRESS
ATTORNEY: Lawyer ……………
ADDRESS
DEFENDANT: C….. D…. (T.R.:………..)
ADDRESS
CASE VALUE: 1,000,00 TL (For now)
D. SUBJECT: For now, 1,000,00 TL consists of our demand for ecrimisil (unjustified occupation) compensation.
OUR EXPLANATIONS
1. The defendant party, Ankara …. Notary Public, …/…/2021 Date, ….. Promised Sale of Real Estate with Journal Number, Ankara Province Batıkent District … Island ….Parcel… No ….Neighborhood ….Cad No:…/…. The plaintiff committed to sell the immovable property in .
2. Pursuant to the aforementioned undertaking, the immovable has been transferred at the Yenimahalle Land Registry Directorate on …/…/2021, but 3 months have passed since the transfer, the exact and precise date of evacuation and delivery of the immovable is specified in the immovable sales contract, and the plaintiff client has been repeatedly warned. Despite the fact that the defendant has not vacated the immovable property, he is in the position of unjust occupant.
3. The plaintiff client’s damage arising from this unfair occupation of the defendant party should be compensated. For the reasons explained above, it became necessary to open this case.
LEGAL REASONS :
OUR EVIDENCE:
1-Deed Records
2-Notary Public Notice
3-Court decision
4-Witness
5-Requesting the Rental Fees of Precedent Real Estate from Real Estate Agents, Land Registry Offices and relevant institutions
6-Oath
7-Discovery
8-Expert Review
9- Subpoena of electricity, water, natural gas, internet records
CONCLUSION AND REQUEST: For all the reasons explained above and to be taken into account by your Court ex officio:
1-To be collected from the defendant together with the legal interest of 1.000 TL unjustified occupation compensation (ecrimisilin) for now, without prejudice to our rights regarding the surplus as of ../../2021 as of ../../2021, as specified in the Preliminary Sale of the Real Estate Agreement,
2-We request by proxy that it be decided that all kinds of litigation expenses, fees and attorney’s fees be charged to the defendant. 21.08.2021
Plaintiff’s Attorney
Lawyer
