…TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE
PLAINTIFF : TC No:
address :
attorney :
address :
DEFENDANT :
ADDRESS :
CASE VALUE :
SUBJECT: The Title Deed contains our Registration Request and consists of the submission of our petition.
OUR EXPLANATIONS
1-) My client’s case from … / … / … … purchased with an external sales contract dated in the address located on your parcel with the number registered immovable sq … …/…/… – …/…/… it has a four-storey building constructed between dates. … The value of the building, which costs TL, is currently TL, while the fair value of the real estate on which it is located is TL. The contract of sale … is signed at a price of TL.
2-) Upon the death of the out-of-court defendant, who is a party to the sale agreement, the heirs of the defendants have requested my client to vacate the real estate with the claim of invalidity of the sale agreement and are preparing to file a lawsuit to prevent the sale.
3-) 724 of the law No. 4721. “if the value of the structure is clearly greater than the value of the land, the bona fide party may request that the ownership of the structure and the land in whole or in sufficient part be given to the material owner for an appropriate price.” the conditions stipulated in the judgment have been fulfilled. My client was in a position of good faith during the time the structure was built, and the value of the structure is clearly more than the value of the land. My client also accepts the deduction of TL from the price of the land to be determined, which was agreed in the sale agreement and paid to muris out of court, and is ready to pay this difference to the defendants in case of a difference in price.
4-) For all these reasons, it has been necessary to file a lawsuit with your prisoner with this lawsuit petition to ensure that the ownership of the square meter land registered with the number of parcels … located at the address for a price that the court deems appropriate … is given to my client and registered in the title deed on the client.
LEGAL REASONS : 4721 P. K. m. 19, 722, 723, 724; 6100 P. K. m. 1, 2, 5, 6, 12, 119.
LEGAL EVIDENCE :
1-) external sales contract dated … /… /…,
2-)… at the address … registered with the number of parcels … square meter immovable title deed registration,
3-) Discovery and expert examination,
4-) Probate order,
5-) The witness list shows the names and addresses of the witnesses and the topics they will testify about.
Results and PROMPT : for the reasons we described above, the address is located in the parcel with the number registered immovable for the price … it will be appreciated sq (agreed upon in the contract of sale paid to the deceased by Offset from the case by TL) in accordance with the provisions of applicable law, land registration and cancellation of registration for a decision on behalf of the client, litigation costs and attorneys ‘ fees to the opposite side of yukletilm we will respectfully request on behalf of the client. …/…/…
ADDITIONAL :
Plaintiff Attorney
Lawyer.
You can read our articles and petition examples by clicking here.