Real Estate Registration Request Sample
TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE
THE PLAINTIFF(S) :
TC IDENTITY NUMBER :
ADDRESS :
LEGAL REPRESENTATIVE :
(legal representatives of the parties, if any)
ADDRESS :
(of the legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : It is our request for the registration of the immovable property numbered… Island … Parcel in the name of our client.
EXPLANATIONS :
1-) The immovable property numbered … island … parcel (ANNEX-1), which is the subject of the lawsuit, located in … location, is registered in the title deed in the name of the person named … … who has been declared absent (ANNEX-3) with the decision of the … Civil Court of First Instance dated …/ …/ … and numbered …/ … / … Main and …/ … Decision (ANNEX-2).
2-) Pursuant to Article 713/I of the Turkish Civil CodeNo. 4721; the person who has possessed an immovable which is not registered in the land registry for a period of twenty years without a lawsuit and without interruption and in the capacity of owner, may request the registration of the right of ownership on the whole, part or a share of that immovable in the land registry.
In paragraph II of the same article; the possessor of the whole immovable or a part of the immovable registered in the name of a person whose owner cannot be determined from the land registry or who was declared absent twenty years ago, may also request the registration of the right of ownership on the whole, part or a share of that immovable in the land registry.
3-) The necessity to file this lawsuit has arisen due to the fact that our client has been in possession of the immovable property subject to the lawsuit as the owner for twenty years without a lawsuit and without interruption since the year … (ANNEX-4).
LEGAL GROUNDS : Art. 19, 704, 705, 706, 707, 713, 714, 715, 717, 840, 892, 1008, 1013, 1021, 1023, 1025; Art. 1, 2, 5, 6, 12; Art. 25, 26, 27 of S. 3402
LEGAL EVIDENCES :
1-)Land registry of the immovable property numbered … block … parcel,
2-) …/ …/ … dated …/ …/ … and numbered …/ … Esas and …/ … / … Decision numbered … Civil Court of First Instance decision,
3-) Decree of absenteeism,
4-) Names and addresses of the witnesses and their testimony
witness list showing the issues.
CONCLUSION AND REQUEST : For the reasons explained above, I respectfully request your Honorable Court to decide to register the immovable property with the parcel numbered …. island … in the name of our client, and to award the judicial expenses and attorney’s fee to the defendant. …/…/…
ANNEXES :
1-)Land registry of the immovable property numbered … block … parcel,
2-) …/ …/ … dated …/ …/ … and numbered …/ … Esas and …/ … / … Decision numbered … Civil Court of First Instance decision,
3-) Decree of absenteeism,
4-) The names and addresses of the witnesses and their testimony
witness list showing the issues,
5-) One approved power of attorney sample.
Plaintiff Attorney
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