COURT OF FIRST INSTANCE
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : Preemption lawsuit (….. TL)
FACTS : 1- The plaintiff client is the owner of 1/4 of the immovable property registered under the parcel number …., block …… of the title deed.
2- The other shareholder ………….. sold his share to the defendant on …./…./…… for …… TL.
3- The plaintiff client wants to buy his share from the defendant by using his pre-emption right arising from the law. The sale price has been deposited to the court cashier. In addition, other fees and taxes to be determined will be paid.
4- In order to prevent unavoidable consequences, we also request a precautionary injunction to be placed on the relevant land registry until the end of the lawsuit.
For this reason, it has become compulsory to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Title deed record, witness statement and all kinds of legal evidences.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, I request that the lawsuit be accepted and the immovable share of the defendant be cancelled in the title deed and registered in the name of the plaintiff, a precautionary injunction be placed on the title deed until the end of the lawsuit in order to prevent transfer, and the costs and attorney fees be imposed on the defendant.
I would like to submit my request. Sincerely yours,
Plaintiff’s Counsel
Lawyer………………….
(SIGNATURE)
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