COURT OF FIRST INSTANCE
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : Return of movable property.
FACTS : 1- The …….. brand motorbike. With ……… number plate ……… and chassis number ………… was stolen from. The front of the apartment. Where it was parked on …./…./……. Later, while my client was visiting motorbike dealerships to buy a car. He saw his own motorbike at ……… car dealership. Thereupon, my client told the defendants. In the motorbike gallery that the motorbike in question was his and that it had been stolen about 4 months ago and asked for the return of the motorbike to him.
2- However, the defendants did not approach the said return and were rude to my client and claimed that they had been using the motorbike for many years. Although the defendants knew that the motorbike in question belonged to my client, they did not return the motorbike and said that they could sell the motorbike to him provided that he paid half of the fair market value. This situation also reveals the bad faith of the defendants.
It has become necessary to file this action for the return. Of the property against the defendants who have the motorbike belonging to my client in bad faith.
LEGAL GROUNDS :
EVIDENCE : Motorbike registration, police reports regarding the theft of the motorbike. Criminal case file of the thief who stole the motorbike. Witnesses and all kinds of legal evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above. I request that the lawsuit be accepted and the motorbike. In the possession of the defendants be returned to the plaintiff, and that a ban on the sale of the motorbike. To a third party be imposed on the traffic vehicle registration. In order to prevent the transfer of the motorbike to a third party.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
Av………………….
(SIGNATURE)
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