COURT OF FIRST INSTANCE
Plaintiff : University Rectorate
ATTORNEY :
DEFENDANT
SUBJECT OF THE CASE : Title deed registration case.
FACT : 1- ……, ……. registered immovable. parcel no. ………….. It was expropriated in accordance with the expropriation decision approved by the decision of the Rectorate of the University dated …./…./…… And numbered ………… and within the framework of the provisions of the regulation. Law numbered ……
2- Expropriation fee ………….. Bank, …….. Account numbered at ………. branch………. It is in the name of the Bank on behalf of the defendant and is attached.
3- Although the expropriation decision was notified to the defendant via notary on …./…./……, the defendant has not applied to the judicial or administrative jurisdiction against the expropriation proceedings and has not yet completed the title deed transactions on behalf of my client.
In order to register the immovable property in question in the name of the plaintiff administration. It has become mandatory to file this lawsuit.
LEGAL GROUNDS
EVIDENCE : Expropriation documents, bank receipt, discovery etc. evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, with the acceptance of our lawsuit. ….. sy. I request that our lawsuit be accepted. And the immovable in question be registered in the name of the plaintiff administration. And that the litigation expenses and attorney’s fees be collected from the defendant.
I would like to submit my request, sincerely,
Plaintiff Lawyer
Lawyer ………………….
(SIGNATURE)
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