TO THE CIVIL 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: We want to prevent the temporary confiscation of the immovable property that was confiscated without expropriation.
CASE VALUE :
(In cases related to property rights)
INSTRUCTIONS :
1-) …… location, ……………..address…….. name, …. the title deed of the parcel is registered on behalf of our immovable Client. (APPENDIX-1)
2-) The defendant …/…/….. in its history, it has intervened in real estate by investing in real estate by disposing of it without expropriation without relying on a justified and valid reason.
3-) Since there is an intervention in terms of some of the real estate in question, our client has no opportunity to use or save the rest of the real estate.
4-) In order for our client to make the transfer to the defendant party obsolete ……… Notery of …./…./….. date ….. numbered he has sent his warning (ANNEX-2). However, the defendant did not take into account the warnings in question.
5) In order to prevent and restore the damage to our client’s real estate, it has been necessary to apply to your Court.
LEGAL REASONS : 4721 P. K. m. 683; 6100 Pp. K. m. 12, 199; 2942 P. K. m.11.
LEGAL EVIDENCE :
Land Registry
…….. Noterligi of …./…./….. date ….. evmiye no.lu warning
Expert
4.Discovery
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request on behalf of our client that it be decided to prevent and reinstate the damage to our Client’s real estate, to charge the attorney’s fee and trial expenses to the opposite party. …/ …/ …
APPENDICES : 1. Land Registry
…….. Notary of …./…./….. date ….. numbered warning
An example of a certified power of attorney.
Plaintiff’s Attorney
