TO THE COURT OF FIRST INSTANCE
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT :Bona Fide 3.it consists of a request for compensation for the damage suffered by our client, who is in the position of a person, due to the cancellation of the title deed to the real estate subject to the lawsuit, and the amount of real estate paid to the defendant …… TL.
CASE VALUE :
(In cases related to his assets)
INSTRUCTIONS :
1-)Our client rented apartment no……. belonging to the defendant …./…./…. history …. He bought it for TL. (APPENDIX – 1)
2-)After our client buys the real estate that is the subject of the case, the real estate that has a cost ….. The defendant …. The Bank …. The Branch ….. he deposited it into his account and took the title deed of the immovable property on it. (APPENDIX – 2)
3-)Again, regarding the immovable property, which is a real person out of the case ….. title cancellation and registration lawsuit filed by the company alleging that the real estate was sold with a fake power of attorney and an irregular transaction ……… The Court…./…/… has been accepted by the dated decision and the registration made on behalf of our client in the title deed has been canceled. (APPENDIX – 3)
4-)Our client is subject to Article 1023 of the Civil Code.according to the article, the subject of the lawsuit is the bona fide third party who bought the real estate from the defendant and is unable to know that the defendant has made a transaction with a fake power of attorney, because the defendant is a relative of our client and based on the trust relationship between them, our client did not conduct a detailed investigation of the decency of the power of attorney before buying the real estate.
6-) For all these reasons, 4721 p. K. m. in accordance with the provision of 1023, the client was obliged to open this case in order to ensure compensation for the damage suffered and the compensation of the real estate paid from the defendant defendant.
LEGAL REASONS : 4721 P. K. m. 1023.
LEGAL EVIDENCE :
1-)Land Registry Records
2-)Bank Statements
3-)……. The Court…./…/… the decision on cancellation and registration of the dated land registry
4-)Expert Review
Results and PROMPT :for the reasons we described above, the defendant reserved the right to be on the surplus, total …… TL to be convicted to pay compensation, (Case value for the prompt, “the surplus is stored on keeping rights” or whether or not the value of the contested case matters; prepared on the topic of litigation can vary according to the petition, although you should be evaluated based on claims about a concrete case.)we respectfully request from your Supreme Court that it be decided that the costs of the trial and the power of attorney should be charged to the opposite party. …/…/…
ADDITIONAL:
1-)Land Registry Records
2-)Bank Statements
3-)……. The Court…./…/… the decision on cancellation and registration of the dated land registry
4-) An example of a certified power of attorney.
