… TO THE JUDGE OF THE COURT OF FIRST INSTANCE

PLAINTIFF :

TC IDENTIFICATION NUMBER :

ADDRESS :

Deputy :

(Legal representatives of the parties, if any)

ADDRESS :

(Legal representatives of the parties, if any)

DEFENDANT :

Address :

Subject: Good 3.it consists of compensation for the damage suffered by our client, who is in the position of a person, due to the cancellation of the title deed of the subject of the case, and a request for the rest of the TL, which is the real estate price that he paid to the defendant.

LITIGATION VALUE :

(In cases related to his assets)

INSTRUCTIONS :

1 -) our client belongs to the defendant …… apartment no …./…./…. history …. He bought it for TL. (Annex-1)

2 -) after our client buys the real estate that is the subject of the lawsuit, the real estate price….. TL is the defendant’s…. Bank …. Branch ….. he deposited it in his account and took the deed to the real estate on it. (Annex-2)

3 -) again, as for the relocation, which is a real person who is not sued ….. a case for the cancellation and registration of the title filed by the claim that the real estate was sold by a fake power of attorney and an irregular transaction……. Court …./ … / … has been accepted by the dated decision and the registration on behalf of our client in the deed has been cancelled. (Annex-3)

4 -) Our Client 1023 Of The Civil Code.according to the article, the subject of the case is a bona fide third party who purchased the real estate from the defendant and cannot know that the defendant made a transaction with a fake power of attorney, because the defendant is an acquaintance of a relative of our client, and based on the trust relationship between them, our client did not conduct a detailed investigation into the forgery of the power of attorney before purchasing the real estate.

6 -) for all these reasons 4721 S. K. m. In accordance with provision 1023, it is necessary to open this case to ensure that the client is compensated for the damage suffered and that the real estate value paid is at rest from the defendant.

Legal reasons: 4721 P. K. m. 1023.

LEGAL EVIDENCE :

1 -) Land Registry Records

2-) Bank Statements

3-)……. Court …./ … / … dated deed cancellation and registration decision

4 -) Expert Examination

Results and PROMPT :for the reasons we described above, the defendant reserved the right to be on the surplus, total …… TL to be convicted to pay compensation, (Case value for the prompt, “the surplus is stored on keeping rights” or whether or not the value of the contested case matters; prepared on the topic of litigation can vary according to the petition, although you should be evaluated based on claims about a concrete case.)we respectfully request your Supreme Court to decide whether to charge trial costs and power of attorney fees to the other party. …/…/…

ADDITIONAL:

1 -) Land Registry Records

2-) Bank Statements

3-)……. Court …./ … / … dated deed cancellation and registration decision

4 -) one sample of approved power of attorney.

Acting Plaintiff

Lawyer