……. TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : PREVENTION OF SEIZURE DUE TO UNLAWFUL OCCUPATION AND WITHOUT PREJUDICE TO OUR RIGHT TO CLAIM AND SUE FOR MORE ……. ABOUT OUR CLAIM FOR ECRIMİMİSİL.
EXPLANATIONS :
1-Our client ……. purchased the immovable property at the address ……. owned by the defendant ……. from the defendant.
2-The defendant declared that he would vacate the house while selling the property he owned and lived in to our client, whereupon our client bought the apartment. However, after the defendant sold the house to our client, he did not vacate the house and continued to live there. Despite all the warnings of our client, he continues to sit and does not pay a fee for this.
3- Our client has been victimised due to the defendant’s failure to evacuate the property in question. Our client did not allow the defendant to live in the flat he bought. In the face of this situation, our client can neither use the apartment he has purchased nor benefit from its benefits.
4-The defendant is unlawful occupation and it has become necessary to file this lawsuit in order to prevent its unjust intervention.
LEGAL GROUNDS : Civil Code, Civil Procedure Code and Related Legislation
EVIDENCE :
Land Registry, Witnesses, Discovery and Expert Examination, Other Legal and Discretionary Evidence etc.
RESPONSE TIME : 10 Days
CONCLUSION OF THE REQUEST : For the reasons stated above, we request that the defendant’s unjustified seizure be prevented and that, without prejudice to our right to claim and sue for more, the collection of ……. ecrimisil together with legal interest from the date of intervention due to the wrongful use of the immovable property, the defendant be charged with the costs of the proceedings, and that the counterparty attorney fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Law No. 1136 Law No. 4667 amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF …….
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