TO THE COURT OF FIRST INSTANCE
PLAINTIFF:
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : ARTICLE 10 of the Expropriation Law No. 2942. according to the article, it consists of a request for registration of the real estate in the name of the client and registration of the title deed.
INSTRUCTIONS :
Our client is the administration, the defendant ……………………. located in the …………… The Province, ………… District, Gençler Mahallesi, ……………. Real estate located on the street …./…./……. date and …/….. it has been expropriated by a numbered decision. (APPENDIX – 1)
The expropriated immovable property is not registered in the title deed, and the real estate has a ……………… the acquirer has acquired ownership of the immovable property with the statute of limitations.
Our client, it is the price of expropriation…………………………….-TLyi ………………….. The Branch …………… he has deposited it into account No. (APPENDIX – 2)
The obligation to request the determination and registration of the expropriated real estate on behalf of our client has arisen.
LEGAL REASONS : 2942 P. K. m. 10, 11
LEGAL EVIDENCE :
1- ../…/….. history and …./…./…. numbered expropriation decision,
2- Bank receipt,
3- Administrative investigation minutes
4- Expert Review
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request on behalf of our client that the real estate subject to the case be taken back from the defendant and the title deed registration be cancelled and registered on behalf of the client; the trial costs and the attorney’s fee be decided to be charged to the other party. …/ …/ …
Plaintiff’s Attorney
ANNEXES :
1- ../…/….. history and …./…./…. numbered expropriation decision,
2- Bank receipt,
3- Administrative investigation minutes
4- An example of a certified power of attorney.
