TO THE COURT OF FIRST INSTANCE

PLAINTIFF:

ATTORNEY:

DEFENDANT :

SUBJECT OF THE LAWSUIT : Right of passage facility.

EVENTS : 1- The plaintiff client is engaged in farming. My client … bought a field a month ago. Between the field he bought and the Declivity….. there is a distance of meters. The area between these distances belongs to the Decider. My client is obliged to pass through the defendant’s field in order to use his real estate.

2- The person from whom my client bought the field has actually used it to cross the defendant’s field for many years. However, the defendant did not provide the same opportunity for my client. He turned all sides of the field with a wire to prevent my client from passing through the field. The road between the plaintiff and the field …..to be able to travel the distance of meters … Km. he has to get around.

3- It will be installed ….. for the meter-wide road ….. My client is ready to pay TL compensation.

For these reasons, the obligation to open this case has arisen.

LEGAL REASONS :

EVIDENCE: Land registry records, witness, discovery, expert witness and all kinds of evidence.

CONCLUSION AND CLAIM: According to the reasons presented above and the evidence shown, I wish that with the acceptance of our case, a decision will be made on the establishment of a right of passage in favor of the plaintiff on the defendant’s real estate in exchange for compensation.

Kindest regards,

Plaintiff Attorney

………………….

(SIGNATURE)

ADDITIONAL:

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