… TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE
prosecutor :
TURKISH ID NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT :Benevolent 3.it consists of the claim of TL, which is the compensation of the damage suffered by our client, who is in the position of a person, due to the cancellation of the title deed to the immovable property subject to the lawsuit, and the immovable price paid to the defendant …….
CASE VALUE :
(In cases related to property)
descriptions :
1-) Our client owns the defendant’s ……apartment …./…./…. history …. He bought it for TL. (October – 1)
2-) After our client has purchased the immovable property that is the subject of the case, the immovable value is ….. The defendant’s TL …. Bank…. Branch …..he deposited it into his account and took the title deed of the immovable property on it. (October – 2)
3-) Again, regarding the mentioned immovable property, which is a real person outside the case ….. title deed cancellation and registration lawsuit filed by the real estate with the claim that it was sold with a fake power of attorney and irregular transaction ……. Of the Court …./… /… has been accepted with the dated decision and the registration made on behalf of our client in the deed has been canceled. (October – 3)
4-) Our client is 1023 of the Civil Code.within the scope of the article, the subject of the case is the bona fide third party who purchased the real estate from the defendant and is in a position not to know that the defendant has made transactions with a fake power of attorney, because the defendant is known to a relative of our client, based on the relationship of trust between our client did not conduct a detailed investigation on the Decency of the power of attorney before purchasing the real estate.
6-) For all these reasons, 4721 p. K. m. pursuant to the provision of 1023, the obligation to file this case has arisen in order to provide compensation for the damage suffered by the client and the claim of the immovable property price paid from the defendant defendant.
LEGAL REASONS : 4721 p. K. m. 1023.
LEGAL EVIDENCE :
1-) Land Registry Records
2-) Bank Statements
3-)……. Of the Court …./… /… dated deed cancellation and registration decision
4-)Expert Examination
Results and PROMPT :for the reasons we described above, the defendant reserved the right to be on the surplus, total …… TL to be convicted to pay compensation,(Case value for the prompt, “the surplus is stored on keeping rights” or whether or not the value of the contested case matters; prepared on the topic of litigation can vary according to the petition, although you should be evaluated based on claims about a concrete case.) we respectfully request that the Supreme Court decide to impose the costs of the trial and the proxy fee on the other party. …/…/…
ADDITIONAL:
1-) Land Registry Records
2-) Bank Statements
3-)……. Of the Court …./… /… dated deed cancellation and registration decision
4-) One approved power of attorney sample.
Plaintiff Attorney
Lawyer.
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