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 : Request for Elimination of Stakeholders in the Real Estate
consists of.
DESCRIPTIONS :
1- Our client, together with the defendants, has built a two-storey summer house on the immovable registered in the title deed in the subject of the lawsuit … City, … District, … District, … Island, … Layout, … parcel. (Appendix 1) There are also orange and grape orchards on the immovable, the area where our client built the building and other parts are used as if they were actually divided among the stakeholders. While the real estate has been used by all stakeholders without any problems for years, after the construction of the house was completed, other stakeholders started to cause problems in terms of use, and the continuation of the partnership became unbearable for our client.
2- The sharing of the immovable between the parties with the consent of the parties was not possible due to the unwillingness to pay the value of the building. However, the reinforced concrete building on the immovable has been built entirely with the expenditures of our client’s personal assets and his personal effort. (Appendix 2) On the other hand, there is an annotation in the title deed that the building belongs to our client (Appendix 3) and all stakeholders agree on this issue. (Appendix 4)
3- It has become necessary to apply to your court to ensure that the immovable is divided exactly, if possible, and if it is not, to decide on the dissolution of the partnership through sale, provided that the cost of the assets is left to the client.
LEGAL REASONS: 4721 S. K. m. 698, 699, 6100 S. K. m. 4, 12, 316
LEGAL EVIDENCE: Land registry dated …/ …/ …, dated …/ …/ …
bank loan agreement, invoice dated …/ …/ …
and five invoices dated …/ …/ …
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request on behalf of our client that the partnership in the immovable property be resolved primarily through distribution, if it is not possible, through sale, provided that the value of the building is left to the client, and that the court costs and attorney’s fees be charged to the parties in proportion to their shares. …/ …/ …
Plaintiff’s Attorney
Lawyer
ATTACHMENTS: 1- Title deed registration dated …/ …/ …
2- Bank loan agreement dated …/ …/ …, invoice dated …/ …/ …
and 5 invoices dated …/ …/ …
3- Witness statement regarding the ownership of the real estate to our client
4- One copy of approved power of attorney
