COURT OF FIRST INSTANCE
The Plaintiff : University Rectorate
ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Title deed registration case.
FACTS : 1- The immovable immovable registered in ……, ……. parcel number, ………….. was expropriated in accordance with the expropriation decision approved by the decision of the Rectorate of the University dated …./…./…… and numbered ………… and within the framework of the provisions of the law numbered ……
2- Expropriation fee ………….. Bank, …….. ………. numbered account at the branch of ………. Bank on behalf of the defendant and attached hereto.
3- Although the expropriation decision was notified to the defendant through a notary public on …./…./……, the defendant has not applied to the judicial or administrative jurisdiction against the expropriation transactions and has not yet completed the title deed transactions on behalf of my client.
In order for the said immovable to be registered in the name of the plaintiff administration, it has become mandatory to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Expropriation documents, bank receipt, discovery etc. evidence.
CONCLUSION AND REQUEST : With the acceptance of our lawsuit according to the reasons and evidence presented above, ….. sy. I request that our lawsuit be accepted and the said immovable property be registered in the name of the plaintiff administration and that the defendant be charged with the costs of the proceedings and attorney’s fees.
I would like to submit my request. Sincerely yours,
Counsel for the Plaintiff
Atty………………….
(SIGNATURE)
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