… TO THE JUDGE OF THE COURT

PLAINTIFF :

ADDRESS :

Acting :

ADDRESS :

DEFENDANT :

ADDRESS :

Subject: the collection of the damage suffered due to the defective product consists of our request.

INSTRUCTIONS

1 -) Our client, …. within the boundaries of and …. located in the area around …. the real estate in the nature of plot numbered parcel … / … / … with the decision of the council dated (Annex 1) … / … / … the respondent mayoralty on the date of ….. – He bought it by paying TL. (Appendix 2)

2 -) to make construction on the land purchased …/…/… on the respondent mayoral application (Annex 3) of our client’s application in question, landslide zone <disaster area> landslide in the boundaries of the construction permit will not be given because of the response. (Appendix 4)

3 -) our client cannot benefit from the real estate in this form; he cannot realize the idea of living in the real estate that he has dreamed of for years and that he will retire on the land he has purchased for this purpose with the pension bonus he deserves.

3 -) Turkish Code of Obligations No. 6098 219. in accordance with the article “seller is responsible for the absence of the qualities declared against the buyer in any way, as well as for the existence of material, legal or economic shame which is contrary to the quality or quantity affecting the quality, which eliminates or significantly reduces the value and benefits expected of the buyer for the purpose of use. “Maksut interest statement means the ability of the seller to use it for the relevant issue. Because the purpose of the person who buys real estate in the nature of land, is to build a building in this place. According to the existing legal regulations, the Prohibition of building on the place in question should be considered as a legal shame for the land. In addition, it should not be kept out of sight that there is no need to make a commitment and that the defendant has made a clearly legal defective sale, in the face of the fact that the land sold must be made a building by the purchaser or that it will be saved in a similar manner. Expert and exploratory examinations by your court will also serve to clarify the matter.

4 -) in order to decide the collection of the damages suffered by our client from the defendant, the obligation to open this case arose.

Legal reasons: 6098 P. K. m. 219, 222, 227, 228, 231, 6100 S. K. m. 6, 266, 288.

Legal evidence: 1 -) … / … / … council decision dated,

2 -) … / … / … dated sales contract and payment documents,

3 -) … / … / … application letter to the Defendant dated,

4 -) … / … / … ,

5 -) Expert,

6 -) Discovery

RESULT AND PROMPT

Due to the reasons explained above, our client has suffered due to the land sold in shameful … – TL and will be calculated as of the date of sale …. we respectfully request on behalf of our client that the total …-TL be collected from the defendant and that the trial costs and attorney fees be charged to the other party. …/…/…

Acting Plaintiff