30 Dec REQUEST FOR LIQUIDATION OF THE GOODS REGIME AND COLLECTION OF THE SHARE OF VALUE INCREASE RECEIVABLES
TO THE … FAMILY COURT
PLAINTIFF:
TC IDENTIFICATION NUMBER :
ADRESS:
ATTORNEY:
(Legal representatives of the parties, if any)
ADRESS:
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : Liquidation of the Goods Regime and Collection of Receivables from the Increase in Value
Prompt Consists Of.
CASE VALUE :
(In cases related to property rights)
INSTRUCTIONS :
1-) After our client … …,, married the defendant … … on the date of …/…/… They were divorced by the decision of the Family Court …/…/ dated …/… E, …/… K. (APPENDIX-1)
2-) During the marriage union …/…/… on Dec. 1 meter gold chain, 2 bracelets, 1 pair of earrings belonging to our client were cashed out … … the island … was registered at the parcel … … the square meter of land was purchased and registered in the title deed in the defendant’s name. (APPENDIX-2)
3-) While the marriage union is in progress, our client’s … Bank … Branch … has … TL in the account number. using the above-mentioned plot of land, the defendant completed the rough construction of the one-decker summer house, the fine work was done and the building was ready for use. (APPENDIX-3)
4-) 227 of the Turkish Civil Code No. 4721. the item was included in “the goods of one person, the other person, to obtain protection or improvement or without suitable compensation has been contributed if this property during the liquidation resulting in the contribution shall have the right to take to increase the value, and this value is calculated according to the goods that you will get during the liquidation of the; in the case of a depreciation, the initial value of the contribution is taken as a basis.” in accordance with the provision, there was an obligation to open this case in order to collect from the defendant the contribution of the client to the liquidation of the property regime and the acquisition and improvement of real estate belonging to the defendant.
LEGAL REASONS : 4721 P. K. m. 227, 239
LEGAL EVIDENCE :
1-) … The decision of the Family Court …/…/ dated …/… E, …/… K
2-) …/…/… dated Land Registry Records
3-) Bank records dated …/…/…
4-) Expert review
CONCLUSION AND REQUEST: For the reasons described above, the property regime that continues between the defendant and our client during the marriage has been liquidated and the acquisition and decontamination of the real estate in question has been made by the client … TL. we request by proxy on behalf of our client that it be decided that the contribution will be collected from the defendant together with the legal interest to be carried out from the end of the liquidation, that the trial costs and the attorney’s fee will be charged to the other party. …/ …/ …
ANNEXES:
1-) … The decision of the Family Court …/…/ dated …/… E, …/… K
2-) …/…/… dated Land Registry Records
3-) Bank records dated …/…/…
4-) An example of a certified power of attorney.
Plaintiff’s Attorney
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