( … ) TO THE COURT OF FIRST INSTANCE

PLAINTIFF :

TC NO :

Deputy :

ADDRESS :

DEFENDANT :

Address :

Subject: … Island … consists of our request to register the parcel-numbered real estate on behalf of our client.

INSTRUCTIONS

1 – position of the parcel in case No. … immovable … the name deed, in …/ …/ … date and … / based on … / … … Decision No. the decision of the court following the decision about the absence on behalf of the person named is registered.

2 -) 4721 of the Turkish civil code 713/I. according to the article; a person who holds a real estate that is not registered in the Land Registry for twenty years without litigation and without interruption, and as an owner, may request that the right of ownership over all, part or share of this real estate be decided on registration in the land registry.

II of the same article. in the paragraph; maliki may also request that the right of ownership over all, part or share of that real estate be registered in the name of a person who cannot be understood from the land registry or who has made a decision about negligence twenty years ago be decided to register in the land registry.

3 -) due to the fact that our client has possession of the property subject to the lawsuit … for a period of twenty years without a lawsuit and without interruption, it is necessary to open this case.

Legal reasons: 4721 P. K. m. 19, 704, 705, 706, 707, 713, 714, 715, 717, 840, 892, 1008, 1013, 1021, 1023, 1025; 6100 S. K. m. 1, 2, 5, 6, 12; 3402 S. K. m. 25, 26, 27

LEGAL EVIDENCE :

1 -) … island … registration of immovable property with parcel number,

2 -) … / … / … date and … / … basis and … / … Decision No. … decision of the Court of First Instance,

3 -) non-compliance decision,

4 -) a witness list that shows the names and addresses of witnesses and the topics they will testify.

CONCLUSION AND PROMPT

For the reasons explained above, ada … I respectfully request your Supreme Court to decide whether the parcel-numbered real estate is registered on behalf of our client, the trial costs and the attorney’s fee are left on the defendant.