Request For Prevention Of Seizure And Demolition Of Encumbrances
COURT OF FIRST INSTANCE
Plaintiff : A…
Defendant : B…
Subject : Prevention of encroachment and request for demolition of the structure built by the defendant.
Case Value : … TL
Explanations
1. The defendant has seized the immovable property (vineyard, garden, courtyard of the house, etc.) registered in my name in the title deed with … block … parcel numbered …, located in … province, … district, … neighborhood/village, … street, and has unjustly constructed a building and is using that place as ….
2. All verbal and written requests have been rejected and the defendant has insisted on continuing to encroach.
3. The place of encroachment is my property registered in the title deed. Consequently, the defendant does not have any rights. Since he continues his unjust encroachment, it is necessary to file this lawsuit. I also demand the demolition of his construction.
Legal Evidence : Title deed records, discovery, expert examination, witnesses and all other legal evidence
Legal Grounds : TMY 683 and related legislation
Conclusion and Request : I respectfully request and demand that the defendant be prevented from seizing the immovable property registered in my name with the parcel numbered … block … and the demolition of the construction (construction) and the costs to be taken from the defendant by making the necessary examination and trial.
Plaintiff