TO THE CIVIL COURT

 

 

PLAINTIFF :

 

TC IDENTIFICATION NUMBER :

 

address :

 

attorney :

(Legal representatives of the parties, if any)

 

address :

(Legal representatives of the parties, if any)

 

DEFENDANT :

 

SUBJECT: It is related to the cancellation of the title deed and our registration request.

 

CASE VALUE :

(In cases related to his assets)

 

INSTRUCTIONS :

 

1-) … and the … district, town/village, plot…, … name, …in the field of the parcel skilled registered immovable (Annex-1), …/…/… on the date Cadastral studies performed during …/…/… dated … numbered row by performing a title deed, respondent/defendant on behalf of the have been identified (APPENDIX 2). The determination minutes have been finalized on the date of …/ … / ….

 

2-) The relevant real estate was regularly cultivated and mowed by those who were in the possession of our client’s grandfather, then his father, and finally our client for a period of about … a year from the date of registration of the title deed (transfer date) applied during the cadastre. During all this time, there has been no question that the defendant/defendants and/or their superiors had any knowledge of the real estate subject to litigation.

 

October October October 3-) Examples of documents showing that our client has been authorized by other heirs as a representative to open this case, as well as inheritance agreements (Annex-Dec) that reveal the racial relationship between the parent and our client, are included in the appendix (ANNEX-4).

 

4-) The discovery and expert examination that will be carried out by your court at the location of the real estate subject to litigation, as well as the witness statements that we will listen to during the hearings, if deemed appropriate by your Court (ANNEX-5), will clearly reveal the situation.

 

LEGAL REASONS : 3402 P. K. m. 12, 13; 4721 P. K. m. 713.

 

Legal evidence : … province, district and Village/neighbourhood, plot…, … name, …in the field relating to the deed of the registered immovable of the parcel skilled records …/…/… in the determination report dated cadastre, probate sentence, Our client, in relation to the opening of this case in his capacity as a delegate by authorized certifying that the other heirs, witnesses testify, witness list with the names and addresses of the topics that will shows, discovery, and expert review.

 

Results and PROMPT : for the reasons Above we have tried to explain, still registered in the name of the defendant in case the subject matter of land and other immovable immovable in question represent our client cancel the registration to be registered in the name of the heirs, (Case value for the prompt, “the rights of the surplus stored on keeping” matters, contested case, or whether or not the value of; although it may be amended according to the petition prepared on the subject of the case, the relevant requests should be evaluated based on your concrete case.) we request by proxy on behalf of our client that the court costs and trial costs be decided to be charged to the other party. …/…/…

 

ADDITIONS:

 

1-) … land registry records of the province, … district, … village /neighborhood, … pafta, … island, … field-qualified real estate registered on the parcel.

2-) cadastral determination minutes dated …/…/….

3-) Inheritance regulations.

4-) A document indicating that our client has been authorized by other heirs as a representative in connection with the opening of this case.

5-) The witness list shows the names and addresses of the witnesses and the subjects they will testify to.

6-) An example of a certified power of attorney.

 

 

Plaintiff’s Attorney

 

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