……. TO THE HONOURABLE JUDGE
REQUEST FOR AN INJUNCTION
…….
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : Title Deed Cancellation and Registration
VALUE : …….
EXPLANATIONS :
1-Our clients are the children of a family with 6 siblings. Our clients lost their father a long time ago and Ayşe, being the youngest, had to take care of the care and treatment of her elderly and sick mother at home. She suffered from diabetes, high blood pressure and memory loss for many years and died 3 months ago at the age of 96. (the certificate of inheritance is attached)
2-Ali, the eldest of the brothers, was unemployed and had bad habits. He was given all the opportunities in his father’s lifetime, he was given flats and shops when he got married, but he got divorced in a very short time and ate up the properties built on him in an orgy of pleasure.
3-After his father’s death, he frequently received cash from his elderly mother under the pretext of starting a new business and consumed it in gambling.
4-Lastly, our clients ……. We have learnt that our clients sold the ….. m2 immovable property located in ………. village, ……. locality, Pafta: ……., Parcel: ……. for ……….-TL to the father of his wife, whom he later married, with a special sales power of attorney that he received from his 96-year-old mother in an unknown way. We have learnt that our clients’ mothers
5-The purpose of ………… is entirely for personal benefit, and he will live his day by converting this property, which he later missed from other heirs, into money.
6-…………, who purchased the real estate, has no income, and he is also cared for by our client’s brother (ie son-in-law).
7-Therefore, we request the cancellation of this sale transaction, which was carried out in a collusive manner, and its re-registration in the name of the heirs. Again, in order to prevent the malicious defendant from selling the real estate to third parties, we request an injunction to prevent the sale of the real estate with the above-mentioned name, plot and parcel.
LEGAL GROUNDS : BK AND RELATED LAW ARTICLES
EVIDENCE : Land Registry, Inheritance Declaration, Witnesses, all kinds of evidence.
RESPONSE TIME : 10 days
CONCLUSION OF THE REQUEST :
For the reasons explained, in order to prevent the malicious defendant from selling the immovable property to third parties, we request that an injunction be imposed to prevent the sale of the immovable property with the above-mentioned name and parcel, that the registration of the immovable property in the name of the defendant be cancelled, that the costs of the proceedings be imposed on the other party, and that the counterparty attorney fee be awarded on our behalf as an attorney in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
PLAINTIFFS’ COUNSEL
……………..
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