… TO THE JUDGE OF THE COURT
PLAINTIFF (TC No) :
address :
attorney :
address :
DEFENDANT :
address :
SUBJECT: The Collection of the Material Damage Suffered Due to the Defective Appearance of the Goods Includes Our Request and Consists of Our Petition.
OUR EXPLANATIONS
1-) Our client, …. within the limits of and …. located in the area around …. the immovable property, which is a parcel of land numbered … /… /… with the decision of the council dated … /… /… on the date of the defendant from the Mayor Dec ….. -He bought it by paying TL.
2-) In order to build on the land he purchased … /… /… on the date of the defendant’s application to the Mayor’s Office of our client, a reply was given that the construction permit would not be granted due to the fact that the real estate was Decayed within the boundaries of the landslide zone (Disaster-Prone Zone).
3-) our client are unable to benefit from this move; for many, many years dreamed of and planned for this purpose after retirement by saving money on the purchase of the plot-deserved retirement a bonus of moving premises that are made with the thought of failing.
3-) 219 of the Turkish Code of Obligations No. 6098. in accordance with Article “The seller is liable to the buyer for the fact that the qualities he has declared in any way are not present in the sale, as well as for the presence of material, legal or economic defects that contradict the quality or quantity that affects the quality, eliminate or significantly reduce its value for the purpose of use and the benefits that the buyer expects from it. ” What is meant by the maximal benefit statement is the ability of the seller to use it for the matter to which it is related. Because the purpose of anyone who buys immovable property in the nature of a Deckhouse is to build a building on this place. According to the current legal regulations, the prohibition of building on the mentioned place should be considered legally Decriminalizing for the land plot. In addition, it should not be kept out of sight that the land sold must also be foreseen that the buyer will necessarily build a building or make savings in a similar way, in addition, it is not necessary to make a commitment and the defendant has clearly made a legally defective sale. The expert and discovery examinations to be carried out by your court will also serve to clarify the issue.
4-) In order to decide on the collection of the damage suffered by our client from the defendant, it has been necessary to open this case.
LEGAL REASONS : 6098 P. K. m. 219, 222, 227, 228, 231, 6100 P. K. m. 6, 266, 288.
LEGAL EVIDENCE : 1-) ……/…/… the decision of the council dated,
2-) … /… /… dated sales contract and pay documents,
3-) … /…/… letter of application to the defendant dated,
4-) …/…/… dated reply letter,
5-) Expert,
6-) Discovery
CONCLUSION AND CLAIM: The amount that our client has suffered due to the Decently sold land for the reasons we have explained above …-TL and will be calculated from the date of sale …. we respectfully request on behalf of our client that it be decided to collect the total …-TL from the defendant, together with interest, and that the judgment expenses and power of attorney fee be loaded to the other party. …/…/…
Plaintiff Attorney
Lawyer.
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