COURT OF FIRST INSTANCE
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : Prevention and removal of intervention (….. TL)
FACTS : 1- The plaintiff client is the owner of the immovable property registered in the title deed ……., ……… parcel number. This matter is fixed with the attached title deed record.
2- The defendant municipality, on the other hand, stated that the neighbouring parcels have the right to pass through the disputed parcel and in order to ensure the easy use of this right, it poured asphalt on the immovable and made it a road that everyone can benefit from.
3- In order to prevent this seizure, which will result in the elimination or restriction of the right of ownership, it has become necessary to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Land registry, discovery, witness statements and all kinds of evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above. I request that the lawsuit be accepted and the defendant’s intervention to the immovable property be prevented, the immovable property be restored and the costs and attorney fees be charged to the defendant.
I would like to submit my request. Sincerely yours,
Plaintiff’s Counsel
Av………………….
(SIGNATURE)
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