… FAMILY COURT JUDGE
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : Payment of Contribution Receivables Consists of Our Request.
INSTRUCTIONS :
1-) Our client was married to the defendant on the date of …/ …//. At first, their marriage, which went happily, became unbearable due to the fact that the fights, the violence of which gradually increased, became unbearable. Our client has filed a divorce request with the lawsuit he filed on the date of /…// and the Family Court’s / …// date and/… E. …/ … K. by its numbered decision, our client and the defendant have been granted a divorce.(APPENDIX 1) This decision has been finalized without appeal on the date of … / …/….(APPENDIX 2)
2-) Our client is a graduate of the University and has been teaching for several years. Our client continued to practice his profession after the establishment of the marriage union on the date of / …/ and the monthly average is … TL. he has earned income. Our client contributed to the receipt of the numbered independent part located on the island parcel, which was acquired during his stay married to the defendant and remained on the defendant’s side as a result of the divorce.(APPENDIX 3)
3-) Article 227 of the Turkish Civil Code No. 4721 entitled “Share of Increase in Value”. in the article;
“The goods of one person, the other person, to obtain protection or improvement or without suitable compensation has been contributed if this property during the liquidation resulting in the contribution shall have the right to take to increase the value, and this value is calculated according to the goods during the liquidation of that you will get a loss when it comes to value is based on the value of the initial contribution.”the arrangement is included.
4-) In accordance with the regulation contained in the legislation, … ada … there has been an obligation to contact your court to request the defendant for the contribution made by our client in obtaining the independent section numbered … located on the parcel.
LEGAL REASONS : 4721 P. K. m. 227, 228, 229, 230, 239, 240, 241 , 4787 P. K. m. 4.
LEGAL EVIDENCE : … The history of the Family Court …/…/ … and …/ … E. …/ … K. it shows the numbered decision, the Land Registry Records, the final decision of the local court, the expert witness, the names and addresses of the witnesses and the issues they will testify to witness list
Results and PROMPT : for the reasons we have explained above, …/ …/ … begins …/ …/ … in the history of marriage and divorce, which ended with a divorce in the Union as a result of the defendant acquired the parcel number in the name section … … the rest of the independent contribution to our client in exchange for the defendant is taken from TL to our client and provision, litigation costs and attorneys ‘ fees to the opposite side of yukletilm to be determined, we respectfully request on behalf of our client. …/ …/ …
APPENDICES : 1. OCTOBER 2018 ….The Family Court…./…. E. …/…. K.Notice No.
2.Final interpretation of the Local Court decision
3.Land registry of the immovable property subject to litigation
4.It shows the names and addresses of the witnesses and the topics they will testify to witness list
- An example of a certified power of attorney.
Deputy Plaintiff
