… TO THE JUDGE OF THE COURT OF FIRST INSTANCE;

No file : … / E….

PRIMARY INTERVENTION

REFERENCES :

TC IDENTIFICATION NUMBER :

ADDRESS :

Deputy :

(Legal representatives of the parties, if any)

ADDRESS :

(Legal representatives of the parties, if any)

DEFENDANT :

Deputy :

(Legal representatives of the parties, if any)

ADDRESS :

(Legal representatives of the parties, if any)

DEFENDANT :

Deputy :

(Legal representatives of the parties, if any)

ADDRESS :

(Legal representatives of the parties, if any)

LITIGATION VALUE :

(In cases related to the subject matter of the case and the rights of assets)

Subject: our petition includes our original request for intervention.

INSTRUCTIONS :

1 -) Your Court ../ … / … date and … / …the plaintiff of the case being considered through the case file registered in the Treasury, the subject of dispute and … province, … district, … district / village, … pafta, … island, … parcel of the universe … the real estate is not registered in the title deed, the defendant has confiscated the property, the Prevention of confiscation, the cancellation of the title deed and the registration request.

2 -) The defendant, who stated that the subject of the case was the owner due to the external purchase and transfer of the property, requested the dismissal of the case.

3 -) the subject of the case is not real, our client inherited it from his father. The certificate of inheritance related to this has been submitted to the examinations of your court in the annex to our petition (Annex 1). As can be seen from the inheritance document, muris left only his children, our client, and his brother. And our client’s mother died a long time ago. (Appendix 2)

4 -) Our client bought his brother’s share from his brother with an external sales agreement (Annex 3) dated and became a bell to move alone. Contrary to the claims of the plaintiff and the defendant, the subject of the lawsuit is immovable, used by my client for more than twenty years with the intention of becoming an owner, and has been regularly planted and harvested by him all this time. This matter will be clarified by the explanations that our local witnesses, whose names and addresses are in the witness list we have submitted in the annex to our petition (Annex 4), will give to your court at the trial stage. We think that they are in support of the witness statements on behalf of our client and then settled in for more than twenty years agriculture bağ-Kur was to be insured by documenting that the type of (Appendix 5), the records of the cooperative and agricultural credit has been available since the year the Chamber of Agriculture (APPENDIX 6) also prove our claim we endure, we are among our signs.

5 -) Furthermore, the immovable subject to the lawsuit is not located within the borders of the forest, nor is it a immovable taken outside the borders of the forest and registered on behalf of the Treasury. Therefore, neither the plaintiff Treasury nor the defendant party has a preferential right on the property subject to the lawsuit. We believe that the immovable property subject to the lawsuit should be registered on behalf of my client, who has already fulfilled the conditions of ownership with an extraordinary statute of limitations.

6 -) for the reasons mentioned above, the aforementioned case was originally obliged to intervene to ensure that the property subject to the lawsuit was registered on behalf of the client.

Legal reasons: 4721 P. K. m. 683, 713, 3402 P. K. Additional. m. 4, 6831 S. N

m.2, 6100 S. K. m. 65.

Legal evidence: inheritance certificate, Family Population Registration example, external sales contract, witness statements, administrative letter indicating that agriculture is insured, registration of the Chamber of Agriculture, registration of the Agricultural Credit Cooperative, discovery and expert examination, oath.

Conclusion and request : for the reasons explained above, we respectfully request on behalf of our client that the decision be made to register the deed on behalf of our client, to charge the trial costs and attorney fees to the defendants, based on the acceptance of our original request for intervention and the legal reason for the extraordinary earning statute of limitations of real estate. …/…/…

Annexes: 1 – … issuance from the magistrate’s Court … / … / … T. …/…. E. …/…. K. certificate of heritage

2 – Family Population Registration Example

3 – … / … / … external Share Transfer Agreement,

4-names and addresses of witnesses and the subjects they will testify

list of witnesses,

5-Agriculture indicates that Vineyard-Kur is insured

… / … / … dated, … numbered administrative letter,

6 – … records of the Chamber of Agriculture, records of the Agricultural Credit Cooperative,

7-one sample of approved power of attorney.

Principal / Plaintiff’s Attorney

Attorney