Immovable Conveyance Request
EXAMPLE OF A PETITION REQUESTING THE DISPOSSESSION OF IMMOVABLE PROPERTY
TO THE JUDGE OF THE …COURT;
THE PLAINTIFF :
TC IDENTITY NUMBER :
ADDRESS :
PROXY :
ADDRESS :
DEFENDANT :
ADDRESS :
CASE VALUE : … TL
(In cases related to property rights)
SUBJECT : It consists of our request for partition of the immovable.
EXPLANATIONS :
1-) The defendant ….., one of the stakeholders of the parcel numbered ….. …. , which is one of the stakeholders of the parcel numbered …., sold a section of …. m2 to our client excluding other stakeholders and our client built a house on this section.
2-) As a result of the lawsuit filed by our plaintiff client against the defendant, with the court decision of the …. Court numbered …/… E. …./… K., …. …. m2 of the parcel numbered …. was decided to be registered in the name of our client.
3-) As such, the part shown with … in the sketch should be separated from the parcel numbered …. numbered parcel, and as a matter of fact, in the letter dated …/…/…/… sent from the …. Municipality, it is stated that it is possible to divide it.
4-) We are obliged to file this lawsuit for the subdivision of the specified part of the immovable.
LEGAL GROUNDS : 4721 S. K. art. 705, 3194 S. K. art. 15, 16
LEGAL EVIDENCES :
1-) Immovable title deed records
2-) ….Court Decree No. …/… E. …./… K.
3-) …/…/…/… dated letter from the Municipality
4-) Expert reports
5-) Discovery reports
CONCLUSION AND REQUEST : For the reasons set out above, we respectfully request on behalf of our client that the immovable property be partitioned and registered in the name of the client, and that the costs of the proceedings and attorney’s fees be charged to the other party. …/ …/ …
ANNEXES:
1-) Immovable title deed records
2-) ….Court Decree No. …/… E. …./… K.
3-) …/…/…/… dated letter from the Municipality
4-) One approved power of attorney sample
Counsel for the Plaintiff
ATTY.
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