Title Deed Cancellation And Registration Case
TO THE HONORABLE COURT
REQUEST FOR PROVISIONAL MEASURES
…….
PLAINTIFFS:…….
ATTORNEY:…….
DEFENDANT:…….
SUBJECT: Cancellation and registration of title deed
VALUE: …….
EXPLANATIONS: 1-Our clients are children of a family with six siblings. Having lost their father long ago, our clients, being the youngest, Ayşe, had to take care of their elderly and sick mother at home. The poor woman, who suffered from diabetes, high blood pressure, and memory loss for many years, died three months ago at the age of 96. (Certificate of inheritance attached)
2-Ali, the eldest of the siblings, is unemployed and has bad habits. While their father was alive, he was given every opportunity, including apartments and shops when he got married, but he divorced very quickly and squandered all the property he had acquired.
3-After their father died, he frequently took cash from their elderly mother under the pretext of starting a new business and gambled it away.
4-Finally, we have learned that he sold the …… m2 property located in ……. Village, ……. District, Sheet:……., Parcel: ……. belonging to our clients to his wife’s father, whom he married later, with a special power of attorney obtained from his 96-year-old mother in a manner unknown to us, for ……….-TL. Our clients’ mother
5-…………’s intention is entirely for personal gain, and he will convert this property, which he later stole from the other heirs, into cash to live off.
6-…………, who purchased the real estate, has no income, and our client’s brother (i.e., his son-in-law) takes care of him.
7-For this reason, we request the cancellation of this fraudulent sale and the re-registration of the property in the name of the heirs. We also request that a precautionary measure be taken to prevent the sale of the real estate specified above by the defendant, who acted in bad faith, to third parties.
LEGAL GROUNDS: CIVIL CODE AND RELEVANT LAW ARTICLES
EVIDENCE: Title Deed, Certificate of Inheritance, Witnesses, all kinds of evidence.
RESPONSE PERIOD: 10 days
RESULT OF THE REQUEST: For the reasons stated above, we request that a measure be imposed to prevent the sale of the real estate specified above by lot and parcel number to prevent the defendant, who is acting in bad faith, from selling the real estate to third parties, that the registration of the real estate in the defendant’s name be canceled, that the costs of the proceedings be borne by the opposing party, Pursuant to the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667, we request that the opposing party’s attorney’s fees be awarded to us as attorneys.
ATTORNEY FOR THE PLAINTIFFS
