………………… TO THE JUDGE OF THE COURT OF FIRST INSTANCE

PLAINTIFF :

ADDRESS :

Acting :

ADDRESS :

DEFENDANT :

Address :

Subject: the request for cancellation of the assignment made through donation.

INSTRUCTIONS

1 -) Our client is still … old and has been on dialysis for about 15 years due to kidney failure. Our client, who needs constant care because of this ailment, does not have any relatives who will provide him with the necessary care.

2-) our client, in order to eliminate the need for continued maintenance, previously registered in his own name on the deed … in the … County neighborhood/village, plot, … the name, … kain … m2 plots in real estate, … noterligi of …/ …/ … number with date and Journal donation contract (Appendix 1) has donated to the municipality. As clearly stated in the “Special Conditions” section of the donation agreement, our client will stay in the nursing home belonging to the said Municipality for 20 years and without any charges in return for the donation he has made and the continuous care service he needs will be provided by the nursing home authorities.

3 -) Our client started to stay in the nursing home belonging to the said municipality shortly after the signing of the said donation agreement. However, after some time, the nursing home administration has advised our client that the fee must be paid for the services provided by the Notary Public’s notice (Annex-2) with the date / … / … and the number of days, so that the accumulated TL fee must be deposited in the account specified within the day, otherwise, he will not be able to stay in the nursing home.

4 -) … / … / … upon this notice, which was communicated to our client on the date, the medical negotiations we have made so far with the nursing home Administration and the municipality regarding the issue have been inconclusive. Although our client has fulfilled the commitment in the forgiveness agreement, the other party is in breach of the maintenance obligation to which he was charged in exchange for the donation. For the reasons described, it is necessary to apply to your court with the request of cancellation of the assignment made by our client through donation.

Legal reasons: 6098 P. K. m. 285, 288, 290, 291, 292, 297, 616

LEGAL EVIDENCE :

1 -) Land Registry records,

2-)….. The notary’s office’s … / … / … dated … and daily-numbered donation agreement,

3 -) … Notary Public’s notice dated … / … / … and daily number

RESULT AND PROMPT

For the reasons described above, I request by proxy that our client’s Notary Public’s office be decided to cancel the appointment with the donation agreement dated / … / … dated and numbered per day, and that the trial costs and the power of Attorney be charged to the other party. …/ …/ …

ECLAIR :

1 -) Land Registry records,

2 – … Notary Public’s … / … / … dated and … non-paid donation agreement,

3 -) … Notary Public’s notice dated … / … / … and daily number

4 -) one approved power of attorney sample

Acting Plaintiff