The Civil Court Of First İnstance
THE PLAINTIFF (S) :
TC IDENTIFICATION NUMBER :
ADDRESS :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT :
Address :
Subject: … Island … consists of the fact that we want the real estate numbered parcel to be registered on behalf of our client.
INSTRUCTIONS :
1 -) in case the parcel … the name of the position (Appendix 1) are not moved by deed, in …/ …/ … date and …/ … based on A and … / … the decision of the court decision No. (Annex-2) with a decision about the absence (EK3) given on behalf of the person named is registered.
2 -) 4721 of the Turkish civil code 713/I. according to the article; a person who holds a real estate that is not registered in the Land Registry for twenty years without litigation and without interruption, and as an owner, may request that the right of ownership over all, part or share of this real estate be decided on registration in the land registry.
II of the same article. in the paragraph; alodiary may also request that the right of ownership over all, part or share of that real estate be registered in the name of a person who cannot be understood from the land registry or who has made a decision about negligence twenty years ago be decided to register in the land registry.
3 -) Our client has the obligation to open this case due to the fact that he has the property of the subject of the case … in possession of it as an owner for twenty years without a lawsuit and without interruption from the year (October-4).
Legal reasons: 4721 P. K. m. 19, 704, 705, 706, 707, 713, 714, 715, 717, 840, 892, 1008, 1013, 1021, 1023, 1025; 6100 S. K. m. 1, 2, 5, 6, 12; 3402 S. K. m. 25, 26, 27
LEGAL EVIDENCE :
1 -) … island … registration of immovable property with parcel number,
2 -) … / … / … date and … / … basis and … / … Decision No. … decision of the Court of First Instance,
3 -) non-compliance decision,
4- ) witnesses will testify with their names and addresses
a list of witnesses that shows topics.
Conclusion and request : for the reasons explained above, I respectfully request that the island … parcel-numbered real estate be registered on behalf of our client, that the trial costs and attorney fees be left on the defendant, that the decision be made by your Supreme Court. …/…/…
ECLAIR :
1 -) … island … registration of immovable property with parcel number,
2 -) … / … / … date and … / … basis and … / … Decision No. … decision of the Court of First Instance,
3 -) non-compliance decision,
4- ) witnesses will testify with their names and addresses
list of witnesses who show topics,
5 -) one sample of approved power of attorney.
Acting Plaintiff
lawyer.
