…… TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our request for cancellation of intervention and compensation.
EXPLANATIONS :1-Defendant’s ……. belonging to our client Province, ……. District, ……. Village, ……. Island, ……. There is an adjacent land next to the land of …. m2 registered to the title deed in the parcel.
2-The defendant, who has established a factory producing construction machinery on his land, has encroached on approximately 100 m2 of the land belonging to our client.
3-Our client had the necessary measurements made and notified the defendant, ……. ……. date and ……. journal numbered notice of ……. Notary Public.
4-The defendant did not even respond to our client. The good faith efforts of our client also did not yield any results.
5-We demand that the defendant’s wrongful encroachment on our client’s land be prevented and that the land be paid for the land.
LEGAL GROUNDS Article 618 of the Civil Code and other provisions.
EVIDENCE : Land registry, discovery, expert examination, witness statements
RESPONSE PERIOD : 10 days.
CONCLUSION OF THE REQUEST : For the reasons explained, to prevent the unfair encroachment by the defendant on the real estate belonging to our client, to demolish the building on the land, to pay our client, who has not been able to use 100 m2 of his land for 18 months since the building was built, a total of ……., which is a monthly rent of ……. to be paid by the defendant together with the legal interest to be processed from the date of the lawsuit, to charge the defendant party with the costs of the proceedings, and to award the counterparty attorney fee on our behalf as a lawyer in accordance with the 164/last paragraph of the Law No. 1136 on Attorneyship Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
…….
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