-EXAMPLE PETITION-
ANKARA SENTINEL MAGISTRATE’S COURT ( )
CAUTION IS IN DEMAND.
REQUESTING
HEIRS : 1-A….. B….. (T.C.:……………..)
2-D….. B…..(T.C.:……………..)
address
attorney :
address
OTHER ARTISTS: 1-….. ….. (T.C.:……………..)
2-….. …..(T.C.:……………..)
SUBJECT OF THE CASE: It consists of our requests to determine the dress code belonging to testator and appoint a representative to this dress code and take measures.
INSTRUCTIONS
Clients who have requested the determination of the term from your Court with this petition A….. B….. and D….. B….. they are brothers and their father is testator C….B…. (addition1) , where the identification information of the testator is presented in the October of the petition../../…. He passed away on his date. addtion 2 October, as can be understood from the inheritance decree (Annex-2) that we have submitted in the annex to the petition, the clients who make the request and the other two people besides the clients are the heirs of the testator .
There is no known will left by testator . Although some of the assets of the testator are known to us, we submit our requests to your Court as follows in order to determine the unknown part of the testators assets.
The assets of the testator known to the clients (October-3) are as follows:
1-
2-
In order to determine the assets of the testator that are unknown to the clients, we request that the following points be determined:
1-By questioning the bank account records of testator , determining the account records and account movements, vehicle and bank deposits and assets and liabilities owned by him jointly or alone
2-Determination of the rights of the testator from official institutions with the tender to be written to the SSI
3-Determination of the assets and liabilities of the land registry records belonging to testator , including transfer transactions, by questioning through TAKBIS
4-Determination of the tax records belonging to the testator by writing to the Revenue Administration as an auctioneer and questioning
5-We demand that the motor vehicles belonging to testator be identified by questioning the active and passive ones.
Since there is an inherited animosity between the plaintiff clients and the other two legal heirs of the testator ; It is thought that situations may arise that will create a loss of rights for the clients by the appearance of the Decency to be determined by your Court in addition to the existing terek. For this reason, in order to prevent the heirs from losing their rights and to protect the integrity of the land, we first request that a measure be taken on the land already known and determined by your Court and that a representative be appointed by your Court to the land in question, as the matters determined must also be kept in order to avoid damage.
LEGAL REASONS: TMK, HMK, Law on Advocacy and other relevant legislation
EVIDENCE: testator population registration information, Inheritance decree, Land registry records, expert report, etc. all delail
CONCLUSION AND CLAIM : With all the reasons described above and re’ you will be considered by your Court:
1-First of all, to accept our case, which includes the requests listed above,
2-Appointment of a representative to a term that is already known and will be determined by your Court,
3-In this direction, the above-mentioned relevant authorities have been written to the auction and to determine the assets of the testator in the terek
4-In order to prevent the loss of rights of the heirs and to protect the integrity of the estate, measures should be taken on the land already known and determined by your Court,
5-We offer and request by proxy that it be decided that the costs of the trial and the power of attorney will also be met from the court. 27/10/2021
Attorney of Claimants
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