… TO THE COURT OF FIRST INSTANCE JUDGE
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : It is our wish to prevent confiscation of the immovable on which a transformer was built by confiscating without expropriation.
CASE VALUE:
(On property rights cases)
DESCRIPTIONS :
1-) …… location, ……………..… island ….. parcel no. … is registered in the name of our client. (ANNEX 1)
2-) The defendant party intervened in the immovable by constructing a transformer on the immovable by confiscating it without expropriation on …/…/….. without a just and valid reason.
3-) Since there is an intervention in some part of the immovable in question, our client has not been able to use or dispose of the rest of the immovable.
4-) Our client sent the notice of the …….. Notary Public’s Notary Public dated …./…./….. dated ….. journal no. (Annex-2) in order to restore the immovable to the defendant party. However, the defendant did not heed the warnings in question.
5) It has become obligatory to apply to your Court in order to prevent the seizure of our client’s real estate and to restore it.
LEGAL REASONS: 4721 S. K. m. 683; 6100 S.K.m. 12, 199; 2942 S. K. Art.11.
LEGAL EVIDENCE:
Land Registry
Notice of …….. Notary Public dated …./…./….. journal no. …..
Expert
CONCLUSION AND REQUEST: Due to the reasons explained above, we respectfully request, on behalf of our client, that it be decided to prevent the seizure of our client’s immovable property and restore it to its former state, and that the attorney’s fee and litigation expenses be charged to the other party. …/ …/ …
APPENDIX: 1. Land Registry
Notice of …….. Notary Public dated …./…./….. journal no. …..
One copy of certified power of attorney.
Plaintiff’s Attorney
Hunting.