TO THE … FAMILY COURT
PLAINTIFF:
TC IDENTIFICATION NUMBER :
ADDRESS:
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS:
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : The liquidation of the goods regime consists in our request.
CASE VALUE :
(In cases related to property rights)
INSTRUCTIONS :
1-) My client …… after marrying the defendant … … on the date of /…/… They were divorced by the decision of the Family Court …/…/ dated …/… E, …/… K. (APPENDIX-1)
2-) While the marriage union was in progress, 8 bracelets of 22 carat belonging to my client were cashed on the date of /…// and the real estate (ANNEX-2) registered on the island … parcel located at the address was purchased and registered in the defendant’s name.
3-) During the marriage union, 6 bracelets of 22 carat belonging to my client were cashed again and the defendant …….. registered in the name you want.a car with a license plate (APPENDIX-3) was taken. It is clear that my client contributed to both the acquisition of real estate and the purchase of the car by giving his bracelets.
4-) 227 of the Turkish Civil Code No. 4721 for the contribution made by my client due to his personal property on real estate and cars purchased during the period when the regime of participation in the acquired property applies. in accordance with the article, it is said that it will receive an increase in the value of the share.
5-) For the reasons presented, it was necessary to open this case in order to collect the defendant’s contribution to the liquidation of the property regime and the acquisition and improvement of the defendant’s real estate and automobile belonging to the client.
LEGAL REASONS : 4721 P. K. m. 202, 214, 225, 227, 235 4722 P. K. m. 10
LEGAL EVIDENCE :
1-) ….Court ../…E., …./… K. divorce decree no.
2-)….. name ….the land registry of the immovable property registered on the parcel.
3-)….registration of traffic registration of a car with license plates.
4-) Expert review
5-) Shows the names and addresses of the witnesses and the topics they will testify to witness list
CONCLUSION AND REQUEST: For the reasons described above, the property regime that continues between the defendant and the client during the marriage has been decimated and the acquisition of the real estate and the car in question and the improvement of the bilahare has been made by the client … TL. we respectfully request on behalf of our client that it be decided that the contribution will be collected from the defendant together with the legal interest to be carried out from the end of the liquidation, that the trial expenses and the attorney’s fee will be charged to the other party. …/ …/ …
ADDITIONS
1-) ….Court ../…E., …./… K. divorce decree no.
2-) ….. name ….the land registry of the immovable property registered on the parcel.
3-) ….registration of traffic registration of a car with license plates.
4-) Expert review
5-) Shows the names and addresses of the witnesses and the topics they will testify to witness list
6-) An example of a certified power of attorney
Plaintiff’s Attorney
