Request For Prevention Of Interference With Immovable Property As An Arbitrator
TO THE JUDGE OF THE … COURT;
THE PLAINTIFF :
ADDRESS :
VEKILI :
DEFENDANT :
ADDRESS :
ATTORNEY :
SUBJECT : Request for Prevention of the Intervention to the Immovable Property by Your Honorable Judgeship as an Arbitrator.
A P P L A C T I O N S
1-) The defendant administration has seized the land of … m², which is located in … Province, … location, directly opposite the health institution called …, registered on … Island, … Parcel of the title deed and registered in the name of our client administration with …/…/… date, … journal number, in order to build a new … Hospital on it, although it has no interest or right.
2-) Neither the defendant administration nor the Ministry of Health has any right on the immovable property in question. As a matter of fact, while my client administration has moved the materials for the new Special Administration building to the land in question in accordance with the order dated …/…/…/…dated and numbered … from the Ministry of Interior to which it is affiliated, it is completely unfair and unlawful for the defendant administration to seize the land.
3-) For this reason, it has become imperative to request your honorable court to examine the case of prevention of seizure as an arbitrator in accordance with the provisions of Law No. 3533 in order to remove the intervention of the defendant administration in the land, which it has no right to do so.
LEGAL GROUNDS : Article 1 of Law No. 3533
LEGAL EVIDENCES :
1-) Title deed record
2- ) Ministry Order
3-) Witness statement
CONCLUSION AND REQUEST : For the reasons explained above, we request a decision to prevent the intervention made by the defendant administration to the immovable property registered in the name of our client administration as an arbitrator, and to impose the costs of the proceedings on the defendant. …/…/…
Counsel for the Plaintiff
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