TO THE … CIVIL COURT
PLAINTIFF:
TC IDENTIFICATION NUMBER :
ADDRESS:
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS:
(Legal representatives of the parties, if any)
DEFENDANT : 1-) Treasury
2-) Forest Administration
SUBJECT : It consists of our registration request for real estate without title deed.
CASE VALUE :
(In cases related to his assets)
INSTRUCTIONS :
1-) … The subject of the lawsuit in the form of a field in his village … and … adjacent to the parcels is immovable, not registered in the title deed. The subject of the lawsuit is located outside the forest cadastre and Article 2 / B application made in the year of immovable property and is one of the places that does not have a forest qualification (ANNEX-1).
2-) The relevant real estate was sold to our client by an external sales agreement (ANNEX-2) dated …/…/ and its ownership was transferred.
3-) Our client, during the intervening … year, has actually decamped to the place in question and has taken advantage of the immovable property by mowing this place down. This situation will be clarified by means of witness statements (ANNEX-3) with the discovery and expert examination to be carried out by your court at the location of the real estate.
4-) For the reasons described, since the conditions for acquiring real estate have been established on behalf of our client through the acquisition statute of limitations, the obligation to apply to your court for the registration of the real estate subject to litigation has arisen.
LEGAL REASONS : 4721 P. K. m. 713; 6831 Pp. K. m. 2.
LEGAL EVIDENCE : An external contract of sale dated /…/… a forest cadastral map, witness statements, reconnaissance and expert examination of the subject of the lawsuit in the form of a field adjacent to the village … and … parcels.
Conclusion and request : for the reasons described above, the subject matter of land registration immovable decision on the case on behalf of our client, a case for the value 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 request by proxy that the decision be made to charge the trial expenses and the power of attorney fee to the other party. …/…/…
ADDITIONAL:
1-) Forest cadastral maps.
2-) An external contract of sale dated /…/ … relating to the subject matter of the lawsuit in the form of a field in the village … and … adjacent to the parcels.
3-) The witness list shows the names and addresses of the witnesses and the subjects they will testify to.
4-) An example of a certified power of attorney.
Plaintiff’s Attorney
