…TO BE A JUDGE OF THE COURT OF FIRST INSTANCE
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
CASE VALUE :
(In cases related to the assets)
SUBJECT : Land Registry Registration Request.
INSTRUCTIONS :
1-) My client’s case from …/…/… external dated sales contract (APPENDIX 1) purchase … the address is located in the parcel with the number registered immovable … sq (APPENDIX 2) …/…/… – …/…/… it has a four-storey building constructed between dates. … The value of the building that costs TL is already … TL, while the fair value of the real estate it is located on is … TL. The sale agreement … has been signed at a cost of TL. (APPENDIX-3)
2-) Upon the death of the defendant, who is a party to the sale agreement (ANNEX-4), the heirs of the defendants have asked my client to vacate the real estate with the claim of invalidity of the sale agreement and are preparing to file a lawsuit for the prevention of elat.
3-) 724 of the law No. 4721. if the value of the structure is clearly greater than the value of the land, the bona fide party may request that the ownership of the structure and all or a sufficient part of the land be given to the owner of the material for an appropriate price.” the conditions stipulated in the provision have been fulfilled. My client has been in good faith throughout the time the structure was built, and the value of the structure is clearly more than the value of the land. My client also accepts the deduction of TL paid to the non-plaintiff murise in accordance with the sale agreement from the amount of the land to be determined, and is ready to pay this difference to the defendants if there is a price difference.
4-) For all these reasons, in order to ensure that the ownership of the square meter plot of land located at the address, registered with the number of parcels … is given to my client and registered in the title deed on the client, in exchange for a price that the court will deem appropriate, it was necessary to open this case.
LEGAL REASONS : 4721 P. K. m. 19, 722, 723, 724; 6100 Pp. K. m. 1, 2, 5, 6, 12, 119.
LEGAL EVIDENCE :
1-) …/…/… external sales agreement dated,
2-)… registered with the number of parcels … registered at the address … land registry of real estate in square meters,
3-)Discovery and expert review,
4-)Inheritance regulation,
5-)The witness list shows the names and addresses of the witnesses and the subjects they will testify to.
Results and PROMPT : for the reasons we described above, the address located in a SQ. for the price … it will be appreciated registered immovable number of the parcel (in the case by the contract of sale agreed upon by Offset from paid … Muris TL) in accordance with the provisions of applicable law, land registration and cancellation of registration for a decision on behalf of the client, litigation costs and attorneys ‘ fees to the opposite side of yukletilm we will respectfully request on behalf of the client. …/…/…
ECLAIR :
1-) …/…/… external sales agreement dated,
2-)… registered with the number of parcels … located at the address … land registry of real estate per square meter,
3-)Discovery and expert review,
4-)Inheritance regulation,
5-)The witness list shows the names and addresses of the witnesses and the subjects they will testify to.
6-) An example of a certified power of attorney.
Deputy Plaintiff
