IN THE COURT OF FIRST INSTANCE
prosecutor:
lawyer’s :
THE DEFENDANT:
SUBJECT OF THE LAWSUIT: It consists of the termination of the sales dictionary and the cancellation of the title deed.
EVENTS :
1- My client ………, ……… located at the address …… the one with the ground floor of the numbered building…… the numbered property has been purchased. prefecture, ……. the district, …… the neighborhood is and ….. island, …… parcel and …….. from the case where the deed deed found in the parcel is the real estate agent who owns the property ……… Against TL, …….. historical sales contract
2- The sales contract between my client and the defendant . Dec…… it was made in history. and the same day …….. date and ………. the title deed numbered yevmiye was given to the Land Registry Directorate. My client, who applied to the Land Registry Directorate, has paid the entire sale price to the case.
3- My client checked the problems that may be in the apartment by making the necessary examinations and examinations when purchasing his apartment. However, after the sales dictionary, my client learned that his apartment was located in a pit in the sewer of the building during the winter with the property of the ground floor apartment that my client purchased while making the necessary preparations to be made. the publication of scents that make apartment residents comfortable is relevant on this …….. He went to the Municipal Zoning Directorate and took the zoning plan of the building and saw the sewage of the building from here. it is located in the lower part of my client’s apartment.
4- My client immediately ……. My client …….. date and …… with the numbered notary public letter, it was immediately notified that the apartment subject to the case sale would take delivery of the apartment with the monthly and sales price file. Despite this, there was no response from the accused…….. A Judge of First Instance ……… D. It was determined that there is a septic tank under the apartment building with Iş’s private file.
5- Please note that my client’s case did not state this defect when selling his apartment, it was taken, the defect was found out later and he did not receive an answer despite informing the defendant immediately, the test was taken, it is difficult to file a lawsuit for termination of the sales contract and cancellation of the title deed.
LEGAL BASES:
EVIDENCE: Land Registry Records, discovery and expert report, transfer of title deed, Witnesses and, if necessary, evidence of Turkish law.
CONCLUSION AND REQUEST: My client with the acceptance of our case for the reasons mentioned above………’ the purchase of the apartment due to the defect of the defective apartment, termination of the sales contract, cancellation of the land registry registration, the lesson of the sale price paid by my client………. It has been decided that the TL, which is the amount of the sales price paid by my client, will be taken from his case and sent to my client, the costs of the trial and the case of the attorney’s country will be decided. ../../..
Prosecutor
Lawyer’s………………….
(SIGNATURE)
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