TO THE COURT OF FIRST INSTANCE;
AN INJUNCTION IS REQUESTED
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
address :
CASE VALUE : … TL
(In cases related to property rights)
SUBJECT : It Consists of a Request for the Return of Real Estate Due to Overcharge.
INSTRUCTIONS :
1-) The client has sold the immovable property (ANNEX-1) located on the parcel (ANNEX-1) registered on the title deed to the defendant … … for a price of TL. (APPENDIX-2)
2-) At the time of the sale transaction, my client had just arrived from the military and was in an economically difficult situation due to marriage preparations. This issue will be clarified by the statements that our witnesses, whose names and addresses are written in the witness list (ANNEX-3), will give in relation to the issue, if your court deems it appropriate. In addition, my client is also inexperienced at his age and does not have information about the real value of the real estate.
3-) The defendant took advantage of my client’s inexperience and being in urgent need to purchase the real estate at the mentioned price.
4-) The real value of the real estate is much higher than this price and we are obliged to open this case in order to ensure the return of the real estate sold under the terms of overcharge.
LEGAL REASONS : 6098 P. K. m. 28.
LEGAL EVIDENCE :1-) Immovable Land Registry
2-) …/…/… dated sale agreement
3-) The names and addresses of the witnesses and where they will testify
the list of witnesses, which shows the subjects,
4-) Expert Witness
5-) Exploration
CONCLUSION AND REQUEST: We respectfully request on behalf of our client that for the reasons set out above, first of all, a waiver of prohibition is placed on the land registry to prevent the transfer of real estate, the real estate’s land registry is canceled and registered on behalf of the client, the trial costs and the attorney’s fee are charged to the opposite party. …/ …/ …
ANNEXES:
Registration of Immovable Land Registry
…/…/… dated sale agreement
It shows the names and addresses of the witnesses and the topics they will testify to witness list
An example of a certified power of attorney.
Plaintiff’s Attorney
