TO THE … COURT’;
prosecutor :
ID NUMBER :
ADDRESS :
attorney :
(Legal representatives of the parties, if any)
DEFENDANT :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
SUBJECT: Request for the Prevention of Interference with Transportation by Your Honor as an Arbitrator.
INSTRUCTIONS :
1-) you are not entitled to, and absolutely nothing to the administration of the defendant, but … With … in position … so-called the health care institution located in the heart of the deed … Name, … in the parcel registered and …/…/… date, … Journal number (Appendix 1) was found to be registered in the name of our client management m2 of land for the construction of the new courthouse has taken a hand.
2-) Both the defendant administration and the Ministry of Justice do not have any rights in the real estate in question. As a matter of fact, while my client has moved materials for the new Special Administration building to the land in question in accordance with the date and order (ANNEX -2) received from the Ministry of Internal Affairs, to which the administration is affiliated, it is completely unfair and unlawful for the defendant administration to confiscate the land.
3-) Therefore, in order to eliminate the interference of the defendant administration in the land that it has unfairly confiscated, even though it has no rights, in accordance with the provisions of Law No. 3533, it has become mandatory to request that your court examine the case of preventing confiscation as an arbitrator.
LEGAL REASONS : 3533 P. K. m. 1
LEGAL EVIDENCE :
1-) Land registry
2- ) Ministerial Order
3-) Witness statement
CONCLUSION AND REQUEST: For the reasons explained above, we request that the intervention made by the defendant administration in the immovable property registered on behalf of our client’s administration be prevented as an arbitrator, that the costs of the trial be charged to the defendant, and that a decision be made. …/…/…
ANNEXES:
1-) Land registry
2- ) Ministerial Order
3-) Witness List
Plaintiff’s Attorney
