… TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE
FILE NO : …/… E.
SUBSTANTIVE INTERVENTION
THE APPLICANT: (TC No):
address :
attorney :
address :
DEFENDANT :
attorney :
address :
CASE VALUE :
SUBJECT : The main intervention includes our request consists of the submission of our petition.
OUR EXPLANATIONS
1) Your court../… /… date and … /… the plaintiff of the case, which is being considered on the basis of the registered case file, the Treasury, the subject of contention and … province, … district, … neighborhood / village, … pafta, … ada, … parcel in the nature of kain … is not registered in the title deed, claiming that the defendant party seized the immovable, the prevention of seizure, cancellation of the title deed and registration has requested.
2-) The defendant, who stated that he is the owner of the immovable subject of the lawsuit due to the external purchase and transfer, requested the dismissal of the case.
3-) The immovable property subject to the lawsuit has been inherited by our client from muristen (his father). The certificate of inheritance related to this has been submitted to the examinations of your court in October of our petition. As can be understood from the inheritance document, Muris …, left behind only his children, our client and his brother …. Our client’s mother, on the other hand, passed away at a much earlier date.
4-) Our client has purchased his brother’s share from his brother with an external sales contract dated … /… / … and has become the sole owner of the property. Contrary to the claims of the plaintiff and the defendant, the immovable property subject to the lawsuit has been used by my client with the intention of becoming the owner for more than twenty years and has been planted and reaped regularly by him for all this time. This issue will be clarified by the explanations that our local witnesses, whose names and addresses are included in the witness list that we have submitted October, will give to your court during the trial phase. We think that they are in support of the witness statements and then arranged on behalf of our client in agriculture for more than twenty years bağ-Kur was to be insured by documenting that wrote the year and the Chamber of agriculture cooperative agricultural credit has been available since the records also prove our claim we endure, we build our signs are.
5-) As such, the immovable property subject to the lawsuit is not located within the forest boundaries, nor is it a real estate registered in the name of the treasury by being taken outside the forest boundaries. Therefore, neither the plaintiff Treasury nor the defendant party has a preferential right over the immovable property subject to the lawsuit. We believe that the immovable property subject to the lawsuit should be registered on behalf of my client, who has already fulfilled the conditions of possession with the extraordinary statute of limitations.
6-) For the reasons mentioned above, it has become necessary to request the obligation to intervene in the aforementioned case with this lawsuit petition in order to ensure that the immovable property subject to the lawsuit is registered on behalf of the client.
LEGAL REASONS : 4721 p. K. m. 683, 713, 3402 Pp. K. Additional. m. 4, 6831 Pp. K
m.2, 6100 PP. K. m. 65.
LEGAL EVIDENCE: Certificate of inheritance, Family population registration sample, External sales contract, Witness Statements, Administrative letter stating that the agricultural bond is insured, Registration of the chamber of Agriculture, Registration of the agricultural credit cooperative, Discovery and Expert examination, Oath.
Results and PROMPT : for the reasons we have explained above, the original request and our acceptance of the intervention with possession of the immovable saver timeout extraordinary legal reason on behalf of our client based on the title deed registration, litigation costs and attorneys ‘ fees to the defendants on behalf of our client, we require that you decided to yukletilm bilvekale with respect. …/…/…
ADDITIONAL :
Principal Respondent / Plaintiff’s Attorney
Lawyer.
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