TO THE CIVIL COURT OF MAGIC
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANTS: 1-
2nd-
ADDRESS :
SUBJECT : It consists of the request for the elimination of the partnership through the establishment of condominium ownership.
OUR EXPLANATIONS:
1-) Our client, together with the defendants, is a stakeholder of the real estate registered in the title deed in … Province, … District, … District, … Island, … Map, … parcel.
2-) The real estate in question has 4 floors and consists of 8 independent sections. The entire structure, which is suitable for the architectural project, is masonry and the independent sections are suitable for use on their own. It will be understood from the land registry records that there is at least one independent section for each stakeholder. The architectural project approved by the municipality (Appendix 2), the building usage certificate (Appendix 3), the photos approved by the municipality (Appendix 4) and the management plan (Appendix 5) are also presented in the annex of the petition.
3-) For the reasons we have explained, an obligation to apply to your court has arisen in order to ensure that the partnership in the said real estate is resolved by establishing condominium ownership.
LEGAL REASONS: 634 S. K. m. 7, 10, 12, 50; 6100 S.K.m. 4, 12, 316, 322
LEGAL EVIDENCE: Land registry dated …/ …/ …, approved …/ …/ …
project, building occupancy certificate dated …/ …/ …, …/ …/
Certified photographs dated …, management dated …/ …/ …
plan
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request, on behalf of our client, that the partnership be resolved by establishing condominium ownership in the aforementioned real estate, by specifying the land shares, and that the litigation expenses and attorney’s fee be charged to the other party. …/ …/ …
Plaintiff’s Attorney
Lawyer
ATTACHMENTS: 1- Title deed registration dated …/ …/ …
2- Approved project dated …/ …/ …
3- Building occupancy certificate dated …/ …/ …
4- Certified photographs dated …/ …/ …
5- Management plan dated …/ …/ …
6- One copy of approved power of attorney
