… TO THE JUDGE OF THE COURT OF LAW,

PLAINTIFF :

TC IDENTIFICATION NUMBER :

ADDRESS :

Deputy :

(Legal representatives of the parties, if any)

ADDRESS :

(Legal representatives of the parties, if any)

DEFENDANT :

Address :

Subject: our petition includes a request for a refund of the price paid to the defendant with cancellation due to the fact that the contract of sale of Real Estate has become impossible to fulfill.

.

LITIGATION VALUE :

(In cases related to his assets)

INSTRUCTIONS :

1 -) between our client and the defendant, … / … / … in the history of … … notarization ….. in accordance with the real estate sale promise agreement (Annex-1) arranged in the form of an official regulation numbered in the journal, The defendant has committed to sell our client an apartment under rough construction. Based on this, our client paid the defendant TL. (Annex-2)

2 -) the contract between our client and the defendant…/…/…. although it was decided to give ferag in the deed in its history, this process was not carried out. (Annex-3)

3-)all the above mentioned issues related to real property sales contract as a result of the evaluation ash as the fulfilment of which it becomes impossible due to the defendant paid to cancellation pursuant to the principle of compensatory justice, as the trial date should be collected from the defendant with the detection by adapting to today’s conditions. For this reason, it was necessary to apply to your court.

Legal reasons: 6098 P. K. m. 146, 4721 S. K. m. 706, 1008, 1009

LEGAL EVIDENCE :

1 -) … / … / … Dated Real Estate Sales Promise Agreement

2-) …/…/…. Payment Receipt

3 -) Land Registry records

Conclusion and claim : for the reasons explained above; … we demand by proxy on behalf of our client that the price paid to the defendant with the cancellation of the contract for the sale of real estate dated by the Notary …/ …/ … is adjusted to today’s conditions as of the date of the case in accordance with the principle of equalizing justice, and that the defendant is charged, trial fees, expenses and attorney fees to the defendant. …/ …/ …

Acting Plaintiff

Lawyer

ECLAIR:

1 -) … / … / … Dated Real Estate Sales Promise Agreement

2-) …/…/…. Payment Receipt

3 -) Land Registry records

4 -) one sample of approved power of attorney