TO THE COURT OF FIRST INSTANCE<\/p>\n
<\/p>\n
THE PLAINTIFF (S) :<\/p>\n
<\/p>\n
TC IDENTIFICATION NUMBER :<\/p>\n
<\/p>\n
address :<\/p>\n
<\/p>\n
attorney :<\/p>\n
(Legal representatives of the parties, if any)<\/p>\n
<\/p>\n
address :<\/p>\n
(Legal representatives of the parties, if any)<\/p>\n
<\/p>\n
DEFENDANT :<\/p>\n
<\/p>\n
ADDRESS :<\/p>\n
<\/p>\n
SUBJECT : … Ada … It Consists in Our Request that the Parcel Real Estate Be Registered on Behalf of Our Client.<\/p>\n
<\/p>\n
INSTRUCTIONS :<\/p>\n
<\/p>\n
1-) … the subject of the lawsuit in his position … is registered on behalf of a person named ada … parcel (ANNEX-1), real estate, title deed, … \/ … \/ date and … \/ … Main and … \/ … Decision of the Court of First Instance (ANNEX-2) and the decision of the winner (ANNEX3).<\/p>\n
<\/p>\n
2-) 713 \/ I of the Turkish Civil Code No. 4721. according to the article; A person who has owned a real estate not registered in the land registry for twenty years without a case and continuously and as a property owner may request that the decision be made to register the right of ownership over all, part or share of that real estate in the land registry.<\/p>\n
<\/p>\n
II of the same article. in its paragraph; The owner may request that the registration of the right of ownership over all, part or a share of the real estate registered in the name of a person who cannot be understood from the land registry or who has been given a wrongful decision twenty years ago be decided in the land registry.<\/p>\n
<\/p>\n
3-) Due to the fact that our client has owned the real estate subject to litigation for twenty years without a case and continuously for twenty years from the year … (ANNEX-4), the obligation to open this case has arisen.<\/p>\n
<\/p>\n
LEGAL REASONS : 4721 P. K. m. 19, 704, 705, 706, 707, 713, 714, 715, 717, 840, 892, 1008, 1013, 1021, 1023, 1025; 6100 P. K. m. 1, 2, 5, 6, 12; 3402 P. K. m. 25, 26, 27<\/p>\n
<\/p>\n
LEGAL EVIDENCE :<\/p>\n
1-)… island … land registry of immovable land with parcel number,<\/p>\n
2-) …\/ … \/ … date and …\/ … Basis and … \/ … Decision no. … Decision of the Court of First Instance,<\/p>\n
3-) The decision of the winner,<\/p>\n
4-) Witnesses will testify with their names and addresses<\/p>\n
the list of witnesses, which indicates the subjects.<\/p>\n
<\/p>\n
<\/p>\n
CONCLUSION AND REQUEST: For the reasons explained above, I respectfully request from your High Court that the real estate numbered 1 parcel be registered on behalf of our client, that the trial costs and the attorney’s fee be left on the defendant, and that the decision be made. \u2026\/\u2026\/\u2026<\/p>\n
<\/p>\n
ANNEXES:<\/p>\n
1-)… island … land registry of immovable land with parcel number,<\/p>\n
2-) …\/ … \/ … date and …\/ … Basis and … \/ … Decision no. … Decision of the Court of First Instance,<\/p>\n
3-) The decision of the winner,<\/p>\n
4-) Witnesses will testify with their names and addresses<\/p>\n
the list of witnesses, which shows the topics,<\/p>\n
5-) An example of a certified power of attorney.<\/p>\n