COURT OF FIRST INSTANCE
(Voluntary Precautionary Mortgage Attachment)
Plaintiff: A……… TC:
Address:
Attorneys:
Address:
Defendants: B………TC:….Address
C………TC:…Address
Case: Sale and cancellation of title deed (cancellation of dispositions)
Instructions:
Defendant C ……… owes our client, the plaintiff, ……….. TL. For this reason, we followed the main file number related to ……… Enforcement Directorate ……… / ………
Immediately before and after the treatment, while continuing, it was stated that the creditors were smuggling that day, and also that the title deed showed that the name ……… was transferred to the real estate parcel numbered B belonging to the other defendant, and that the sale was also shown.
The defendant has been subject to the cancellation of the savings made by the debtor C…………. There is a risk that the plaintiff’s claim cannot be collected. In this case, it is necessary to request the cancellation of the sale and the land registry record on the defendant …………, as well as the restoration of the previous status in the land registry record.
Legal Evidence: Enforcement file, land registry, promissory notes, etc.
Legal Grounds: HR 277, 281, and relevant legislation
Conclusion and Request: We propose and request that the defendant’s savings obtained from the real estate sale made by the debtor ………… to the other defendant ………… be canceled and restored to its previous state, and that the real estate sold be repurchased in accordance with Article 281/2 of the Enforcement and Bankruptcy Law; the costs will be borne by the defendants.
Plaintiff Creditor
Attorneys