Preemption Case
COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Preemption lawsuit (….. TL)
FACTS : 1- The plaintiff client is the owner of 1/4 of the immovable property registered under the parcel number …., block …… of the title deed.
2- The other shareholder ………….. sold his share to the defendant on …./…./…… for …… TL.
3- The plaintiff client wants to buy his share from the defendant by using his pre-emption right arising from the law. The sale price has been deposited to the court cashier. In addition, other fees and taxes to be determined will be paid.
4- In order to prevent unavoidable consequences, we also request an interim injunction to be placed on the relevant land registry until the end of the lawsuit.
For this reason, it has become mandatory to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Title deed record, witness statement and all kinds of legal evidences.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, I request that the lawsuit be accepted and the immovable share on the defendant be canceled in the title deed and registered in the name of the plaintiff, a precautionary injunction be placed on the title deed record to prevent transfer until the end of the lawsuit, and the costs and attorney fees be imposed on the defendant.
I would like to submit this request. Sincerely yours,
Counsel for the Plaintiff
Atty………………….
(SIGNATURE)
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