….. COURT OF FIRST INSTANCE
CLAIMANT : ………….. Municipality Presidency
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : It consists of the request for registration of the expropriated immovable in the name of the administration.
FACTS : 1- On behalf of our administration, the immovable property with ……. parcel number ……., ……. island, …….. district …./…./……, all of which belongs to the defendant, was expropriated on …./…./…….
2- The expropriation price determined by the appraisal value commission for the immovable ……………. TL was deposited to ……………… Bank …………. branch on …./…./…….
3- The expropriation process was finalised and the defendant was notified to transfer the title deed to the defendant on …./…./…… on ……….. Notary Public issued a notice to the defendant to transfer the title deed. Despite this notice, the defendant has not made the transfer.
Therefore, it has become necessary to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Expropriation documents, title deed, bank receipt, notice 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 immovable property be registered to the title deed in the name of the client administration in accordance with the Law No. ….. and that the trial expenses and attorney’s fees be charged to the other party.
I would like to submit my request. Sincerely yours,
Plaintiff’s Counsel
Lawyer………………….
(SIGNATURE)
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