TO THE HONORABLE JUDICATURE
…….
PLAINTIFFS :…….
ATTORNEY:…….
DEFENDANT :…….
SUBJECT : Cancellation and registration of Title deed
VALUE : …….
EXPLANATIONS :1-Our clients are children of a family with 6 siblings. Of our clients who lost their fathers a long time ago, Ayşe had to take care of the care and treatment of her elderly and sick mother at home because she was the youngest. The woman, who suffered from diabetes, high blood pressure and memory loss for many years, died 3 months ago at the age of 96. (the declaration of inheritance october attached)
2-Ali, the eldest of the brothers, is unemployed and has bad habits. He was given all the facilities in his father’s health, he was given apartments and shops when he got married, but he divorced very soon and finished eating the properties built on him in the realm of misery.
3-After his father died, he often took cash and gambled under the pretext of starting a new business from his elderly mother again.
4-Most recently, our clients …….. Village, ……. location, Plot:……., Parcel: ……. also found….. m2 real estate ……….-At a cost of TL, we have learned that he sold it to his wife’s father, whom he later married, with a special sales proxy that he received from his 96-year-old mother in an unknown way. The mothers of our clients
5-…………’ the purpose of which is aimed entirely at personal interests, and he will live his day by cashing in on this property, which he subsequently stole from other heirs.
6-The buyer of the real estate …………’ as he has no income, he is also taken care of by our client’s older brother( i.e. son-in-law).
7-For this reason, we request the cancellation of this sale transaction, which was carried out in an obligatory manner, and its registration on behalf of the heirs again. Again, in order to prevent the malicious defendant from selling the informal property to third parties, we also want measures to be taken to prevent the sale of the above-mentioned informal property.
LEGAL REASONS : ARTICLES OF THE REPUBLIC OF KAZAKHSTAN AND RELATED LAWS
EVIDENCE : Land Registry, Declaration of Inheritance, Witnesses, all kinds of evidence.
RESPONSE TIME: 10 Days
As A RESULT OF THE REQUEST: For the reasons described, in order to prevent the malicious defendant from selling the real estate to third parties, measures should be taken to prevent the sale of the real estate mentioned above, cancellation of the registration of the real estate on behalf of the defendant, transfer of trial costs to the other party, in accordance with the amended Law No. 4667 of the Law No. 1136, 164 / last paragraph of the counterparty proxy fee should be decided on our behalf as a Lawyer we demand that it be given.
PLAINTIFF’S ATTORNEY
