Request For Transfer Of Property
Request for Transfer of Property
.. TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE
THE PLAINTIFF
TC ID NUMBER :
ADDRESS :
PROXY :
(legal representatives of the parties, if any)
ADDRESS :
(legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
CASE VALUE : …….. TL
SUBJECT : It consists of our request for the realization of the transfer of the ownership of the … plate vehicle in the name of our client, which was sold on …./…./…./…. by the … Notary Public on …. with the ….. sales contract issued by the transaction numbered …..
A P P R O C E A T I O N S
1-) The vehicle with license plate …….. and brand …… was sold by the defendant to the plaintiff client on …/…/… date ….. Notary Public No. …… on the date of …/ /…/…..
2-) Although the sale of the vehicle in question has been realized through the notary, the ownership has not yet been transferred to the client. Due to the fact that the ownership has not been transferred, the client does not have any responsibility as the owner of the vehicle subject to the lawsuit
3-) Pursuant to Article 20/d of the Highway Traffic Law No. 2918, the sale of motor vehicles registered in traffic at the notary is subject to certain formal conditions. Accordingly, since the traffic registration record of the vehicle sold at the notary public has not been changed, the buyer of the vehicle in question does not appear as the client in the registration records. Although a notice was sent by us to the defendant in 2006 to change the traffic registration of the vehicle subject to the lawsuit, no response was given to our notice; we tried to reach the seller through different communication channels, but all our efforts to reach the seller remained fruitless. In this regard, the relevant persons whose names are included in the witness list attached to our petition will give explanations regarding the situation, if deemed appropriate by your court
4-) As it is known, the responsibilities arising from the traffic fines and tax debts of the vehicles sold at the notary public but not registered at the traffic registry belong to the former owner of the vehicle. As a result of this regulation, it has become necessary for the client to request a decision to transfer the ownership of the vehicle subject to the lawsuit.
LEGAL GROUNDS : Art. 20 of 2918 S. Code, Art. 2, 6, 10 of 6100 S. Code
CONCLUSION AND REQUEST : For the reasons explained above, …. License plate …. We respectfully request on behalf of our client that the ownership of the vehicle with the license plate be decided to be transferred to the plaintiff client, and that the attorney fee and trial expenses be charged to the other party. …/ …/ …
Counsel for the Plaintiff
ANNEXES 1-) …. made between the parties Notary dated …/…/…/… ….. journal
numbered sales contract.
2-) License certificate.
3-) … Notary Public’s …/ …/ … dated …/ …/ … docket number …
4-) The names and addresses of the witnesses and the subjects they will testify about
witness list
5-) One approved power of attorney sample.
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