Unjust Occupation Petition
TO THE HONORABLE COURT
…….
PLAYER:…….
LAWYERS:…….
DEFENDANT: …….
SUBJECT: PREVENTION OF UNFAIR OCCUPATION AND EXCESSIVE QUANTITY DEMAND,. WHEN OUR RIGHT TO DEMAND IS RESERVED ……. ABOUT OUR COMPENSATION CLAIM
EXPLANATIONS :
1-Our client ……., defendant …….the one that belongs to…… He bought the real estate located at his address from the defendant.
2-The defendant, while selling the property that he owns and resides in to our client, declared that he would vacate the property and our client bought the apartment on it. However, after selling the property to our client, the defendant did not vacate the property and continued to reside there.-The defendant, while selling the property that he owns and resides in to our client, declared that he would vacate the property and our client bought the apartment on it. However, after selling the property to our client, the defendant did not vacate the property and continued to reside there. Despite all the warnings of our client, he continued to reside there and did not pay any rent in return.
3-Our client has suffered damage because the defendant did not vacate the property in question. Our client did not allow the defendant to reside in the flat he purchased-Our client has suffered damage because the defendant did not vacate the property in question. Our client did not allow the defendant to reside in the flat he purchased. As a result, our client is unable to use the apartment he purchased or benefit from the benefitr client has suffered damage because the defendant did not vacate the property in question. Our client did not allow the defendant to reside in the flat he purchased. As a result, our client is unable to use the apartment he purchased or benefit from the benefits of the apartment.
4-The defendant is illegally holding the immovable property, and it has become mandatory to file this lawsuit to prevent his unlawful interference.
LEGAL BASIS:
Turkish Civil Code, Code of Civil Procedure and Related Legislation
EVIDENCE: Title Deed, Witnesses, Examination and Expert Examination, Legal and Other Evidence at Discretion, etc.
RESPONSE TIME: 10 days
CONCLUSION OF THE CASE: For the reasons explained, we demand that the unfair intervention of the defendant be prevented, that the real estate be returned to the rightful owner along with the legal interest of compensation from the date of intervention, as well as the legal interest of compensation arising from unfair use, the legal expenses to be covered by the defendant and the attorney fees of the opposing party be granted to us in accordance with the amended paragraph 164 / last paragraph of the Law No. 1136 by Law No. 4667, without reserving the right to claim compensation and the right to sue. THE CAS