… 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 :

CASE VALUE:…….. TL

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

Subject:…./…./…. history ….. Notary public….. sold under a daily sale contract…. The realization of the transfer of ownership of the license plate vehicle on behalf of the plaintiff client consists of the supply of our request.

INSTRUCTIONS :

1 -) by the defendant…….. license plate and…… brand car, … / … / … on ….. It was sold to the plaintiff client under the contract of sale numbered by the notary.(Annex-1)

2 -) although the sale of the vehicle in question has taken place through a notary, its ownership has not yet been transferred to the client. (Annex-2) due to the fact that the transfer of property has not occurred, the client does not have any responsibility as an owner for the vehicle subject to the lawsuit.

3-a) No. 2918 Highway Traffic Act 20/d motor vehicles registered in traffic, in accordance for sale at the notary, the notary is required and the sale has taken place, and not due to registration of the vehicle change the record in the record of registration of the vehicle in question does not seem receiver as a client. Although a warning (Annex – 3) was issued to the defendant in 2006 to change the traffic record of the vehicle subject to the case by us, no response to our warning was given; we tried to reach him through various roads, but all our efforts to reach him were inconclusive. In this regard, the interested parties whose names are included in the witness list submitted in the annex to our petition (Annex – 4) will give an explanation of the situation if deemed appropriate by your court.

4 -) as is known, the duties arising from traffic fines and tax debts of vehicles that are sold at a notary public but are not registered for traffic registration belong to the former owner of the vehicle. As a result of this arrangement, the client has an obligation to request a decision on the transfer of ownership of the vehicle subject to the lawsuit.

Legal reasons: 2918 P. K. m. 20, 6100 S. K. m. 2, 6, 10

LEGAL LUNATICS :….His notary public office … is numbered in the journal…./ … / … dated sales contract, license, notice of the notary … / … / … dated … Journal, witness statements, oath.

Conclusion and prompt : for the reasons explained above,…. Platter …. We respectfully demand that the decision be made on the transfer of ownership of the trademark vehicle to the plaintiff client, the decision be made on behalf of our client to load the attorney’s fees and trial costs to the opposite party. …/ …/ …

Acting Plaintiff

Attorney

Attachments: 1 -) made between the parties …. His notary’s … / … / … dated ….. wage

numbered sales contract.

2 -) license.

3 -) … note of the Notary Public … / … / … dated … Journal number

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

witness list,

5 -) one sample of approved power of attorney.