COURT JURISDICTION
Plaintiff:
IDENTIFICATION NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
DEFENDANT:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
SUBJECT : Request for the Prevention of Intervention on the Real Estate by Your Honorable Judge in the capacity of Arbitrator.
DESCRIPTIONS :
1-) Although the defendant administration has no interest or right, the title deed located in … Province, … locality, directly opposite the health institution called …, registered in … Island, … Parcel and …/…/… date, … journal number (ANNEX-1) and our client has taken possession of the land of … m² registered in the name of the administration, in order to construct a new … Courthouse on it.
2-) Both the defendant administration and the Ministry of Justice do not have any rights on the immovable property in question. As a matter of fact, my client’s handling of the land by the defendant administration, while the administration has transported materials for the new Special Administration building to the land in question in accordance with the order (Annex -2) with the date …/…/… and number … from the Ministry of Interior, to which it is affiliated, is completely unfair and unlawful.
3-) Therefore, in order to remove the intervention of the defendant administration in the land that it has unjustly seized, although it has no right, it has become mandatory to request your esteemed court to examine the case of prevention of seizure as an arbitrator, in accordance with the provisions of Law No. 3533.
LEGAL REASONS :
LEGAL EVIDENCE:
1-) Title deed registration
2- ) Ministry Order
3-) Witness statement
CONCLUSION AND CLAIM: For the reasons we have explained above, we request that the intervention made by the defendant administration to the immovable registered in the name of our client’s administration be prevented as an arbitrator, that the costs of the proceedings be borne by the defendant, and that a decision be made. …/…/…
ATTACHMENTS:
1-) Title deed registration
2- ) Ministry Order
3-) Witness List
Plaintiff’s Attorney
Lawyer
