Real Estate Registration Petition With Extraordinary Statute Of Limitations
TO THE HONORABLE JUDGE
.......THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT : 1-) Directorate of Finance under the Treasury
2-)……Village Legal Entity
SUBJECT : Our request for registration due to extraordinary statute of limitations.
VALUE OF THE CASE : …….
EXPLANATIONS :1-Our client has been using a field located at ………….. in the village of …………. for more than 30 years continuously and with the title of owner. The real estate is located completely outside the village at the foot of Mount Murat and on the edge of the dried up stream bed called the old stream.
2- No private or legal person or treasury has any right on the real estate in question.
3-We request the registration of this real estate in the title deed in the name of our client who has been using this field as the owner for more than 30 years in good faith and without interruption.
LEGAL GROUNDS : Article 639 of the Civil Code and other articles of law.
EVIDENCE : Witnesses, discovery and all kinds of legal and discretionary evidence.
RESPONSE TIME : 10 days.
CONCLUSION OF THE REQUEST : For the reasons explained, we request that our lawsuit be accepted and the said real estate be registered to the Land Registry in the name of our client, that the costs of the proceedings be charged to the other party, and that the attorney fee of the opposing party be awarded to our name as an attorney in accordance with paragraph 164/last paragraph of the Law No. 1136 on Attorneyship Law amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
