-SAMPLE PETITION-
ANKARA () COURT OF FIRST INSTANCE
PROSECUTOR :
ADDRESS
ATTORNEY :
ADDRESS
DEFENDANT :
ADDRESS
CASE VALUE : 1.000,00 TL (FOR NOW)
D.SUBJECT : At the moment, it consists of our request for compensation of 1,000.00 TL ecrimisil (unfair occupation).
OUR EXPLANATIONS
1.The defendant party, the Ankara we have october in the annex …. Notary Public, …/…/Date of 2021, ….. Evmiye Real Estate Sales Promise Contract with the Province of Ankara Batıkent District … AdaParcel No…. The neighborhood ….Cad No:…/…. ‘de kain has committed to sell the property to the plaintiff client for a fee of 300,000 TL and stated in the said commitment that he will release the property on 2021.
2.In accordance with this commitment …/…/ The transfer of real estate was made in the Yenimahalle Land Registry Office in 2021, but 3 months have passed since the transfer, the date of eviction and delivery of real estate is specified in the contract of sale of real estate exactly and precisely, despite repeated warnings by the plaintiff client, the defendant has not vacated the property, and he is an unfair occupier.
3.It is necessary to eliminate the damage caused to the plaintiff client by this unfair occupation of the defendant party. It has been necessary to open this case for the reasons described above.
LEGAL REASONS: TMK, HMK, TBK, Decisions of the Supreme Court and all other relevant legislation
OUR EVIDENCE :
1-Land Registry Records
2-Notarial Notice
3-Court decision
4-The Witness
5-Asking Real Estate Agents, Land Registry Offices and related institutions about the Rental Prices of Precedent Real Estate
6-The Oath
7-Exploration
8-Expert Review
9-Subpoena of electricity, water, natural gas, Internet records
CONCLUSION AND CLAIM : For all the reasons described above, which will be considered by Your Court if you re:
1-The Promise of Sale of Immovable Property is strictly specified in the contract ../../ provided that we reserve the rights to the surplus from 2021 until the date of the lawsuit, for the time being, we will collect from the defendant the 1.000 TL wrongful occupation compensation (ecrimicillin) together with the legal interest,
2-We request by proxy that all kinds of trial expenses, fees and power of attorney fees be decided to be charged to the defendant party. 21.08.2021
Deputy Plaintiff
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