Petition For Unjustified Occupation
TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT: …….
SUBJECT: PREVENTION OF UNLAWFUL OCCUPATION AND CLAIM FOR EXCESS AMOUNT, WITH OUR RIGHT TO CLAIM RETAINED ……. REGARDING OUR CLAIM FOR COMPENSATION
EXPLANATIONS :1-Our client ……. purchased the real estate located at ……. address, which is owned by the defendant ……., from the defendant.
2-When the defendant sold the property he owned and was residing in to our client, he stated that he would vacate the property, upon which our client purchased the apartment. However, after selling the property to our client, the defendant did not vacate the property and continued to reside there. Despite all of our client’s warnings, he continues to reside there and does not pay any rent in return.
3-Our client has been harmed by the defendant’s failure to vacate the property in question. Our client has not allowed the defendant to reside in the apartment he purchased. As a result, our client is unable to use the apartment he purchased or benefit from it.
4-The defendant is in unlawful possession of the property, and it has become necessary to file this lawsuit to prevent his unlawful interference.
LEGAL GROUNDS: Turkish Civil Code, Code of Civil Procedure, and Relevant Legislation
EVIDENCE: Title Deed, Witnesses, Inspection and Expert Examination, Legal and Discretionary Other Evidence, etc.
RESPONSE PERIOD: 10 days
CONCLUSION OF THE CLAIM: Based on the reasons stated, we request that the defendant’s unlawful interference be prevented, and that the immovable property be returned to its rightful owner, along with the legal interest on the compensation, from the date of interference, with the right to claim additional compensation and the right to file a lawsuit reserved. along with legal interest on the compensation for unlawful use, the litigation costs to be borne by the defendant, and the attorney’s fees of the opposing party to be awarded to us as attorneys in accordance with the amended Article 164/final paragraph of the Attorney Law No. 1136 by Law No. 4667.
PLAINTIFF’S ATTORNEY