… TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE;
PLAINTIFF : TC No:
address :
attorney :
address :
DEFENDANTS :
ADDRESS :
SUBJECT: The determination of possession includes our request and consists of the submission of our petition.
CASE VALUE :
OUR EXPLANATIONS
1-) Our client, …. …. , … province, … district, … village … island … immovable property located next to the parcel numbered field and not registered by the land registry … has been used for agricultural activities for years. … / … / … in the cadastral determination made on the date of, the immovable property that our client uses for agricultural activities, sehven … …. and …. …. it is registered in the name of persons.
2-) These people, who appear to be possessors and whose names have been registered, are also in a fixed state with their own statements that they do not actually have possession.
3-) The discovery and expert examination to be carried out by your court at the location of the immovable property subject to the lawsuit, as well as the witness statements that we will listen to during the hearings, if deemed appropriate by your court, will explain the situation in all clarity.
3-) The cancellation of the wrong registration and the obligation to apply to your Court for the determination of possession has been obtained.
LEGAL REASONS : 3402 P. K. m. 12, 4721 Pp. K. m. 981, 982, 983, 984, 6100 Pp. K. m. 240, 266, 288
LEGAL EVIDENCE : 1. …/ …/ … cadastral detection report 2. Minutes of testimony 3. The witness list shows the names and addresses of the witnesses and the topics they will testify about,
CONCLUSION AND REQUEST : For the reasons we have tried to explain above, we respectfully request bilvekale on behalf of our client to decide on the cancellation of the cadastral determination dated … / … / … and to determine the possession on behalf of the client, to decide on the transfer of trial expenses and power of attorney fees to the other party. …/…/…
eclair :
Plaintiff Attorney
Lawyer.
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