SUPREME COURT…… CIVIL DIVISION
To be forwarded to
CIVIL COURT
Local No. CASE:…./…../……..
MOTION TO CORRECT THE JUDGMENT
PLAINTIFF:
Counsel: Attorney MEHMET AŞIKOĞLU & Attorney SANCAR AKÇOĞLU
GAMZE GÖKÇEOĞLU & ATTORNEY AHMET YASİN YILDIZ
Defendant:
ATTORNEY:
Subject: Supreme Court…… Civil Division…….Background and…………..
…….We request the correction of the decision issued against the ruling to amend case number.
INSTRUCTIONS
The Local Court has issued a decision accepting the case we filed regarding the cancellation of the title deed and registration in the aforementioned case. Although this decision was rendered in accordance with procedure and law, the Supreme Court’s decision does not reflect the truth as a result of the defendant’s objection… The Civil Chamber has overturned the Local Court’s decision due to insufficient investigation and review. While we believe this reversal decision is contrary to the law, we are seeking to have the decision corrected within the prescribed timeframe. That is;
1-) Our client wished to purchase the real estate in question because real estate sales transactions involving foreigners would take a long time. At that time, the sole partner and manager of the aforementioned company executed a power of attorney titled “Assignment Agreement” with …………, thereby transferring all real estate assets to the Company’s bank account. The amount specified in …… Construction Company’s bank account is the SAME as the amount transferred to the bank account of VDNG, the real estate company that owned the property prior to the transfer, in accordance with the power of attorney agreement. …… The real estate registered in the land registry under the name of …… Construction was not transferred to our client after the registration process, and our client, who covered all expenses related to the real estate, thus lost their rights.
2-) State your grounds.
3-) State your reasons.
5 -) For the reasons explained above, in light of the evidence submitted to the case file, the Local Court’s decision is in accordance with procedure and law if the defendant agrees to resolve the dispute. Therefore, it was necessary to request the correction and revocation of. This decision, which seeks to overturn the judgment.
CONCLUSION AND RECOMMENDATION
The reasons explained above and the matters to be considered ex officio;
The correction of your Chamber’s decision dated……….. And numbered ……….. and ……….; the revocation of the annulment decision;. And the confirmation of the Local Court’s decision. Th e decision-making process
depends on the submission and request from the attorney. …./……/…..
DECISION SUBJECT TO THE REQUEST FOR CORRECTION
PLAINTIFF’S ATTORNEYS