…….. COURT OF FIRST INSTANCE
(Injunction Order Exists)
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF THE LAWSUIT : It consists of the request to decide on the nullity of the sale contract dated ………. between the defendants due to collusion.
FACTS : 1- My client, …………, lives in the village and since he does not have enough land to do farming, he uses the tractors in the village for a fee. He decided to buy a tractor with the money he had saved and his uncle, who learnt about the situation, told the defendant ………. that he was a farmer and that he had a farming certificate and that half of the tractor price was covered by the state for those who had a farming certificate.
2- Thereupon, my client allowed the defendant …………. to make a sales contract as if he was buying the tractor himself and the tractor was purchased with the sales contract made with the defendant tractor dealer ………. on ……….. Although the buyer appears to be ……….., the entire cost of the tractor, including the costs of the tractor’s licence transfer procedures, was paid by my client …………..
3- After a certain period of time, ………… and the defendant ………. tried to seize the tractor, claiming that the registration of the tractor was in his name.
4- Since my client knew that part of the tractor price would be covered by the state, he showed his uncle ………, who had a farming certificate, as the buyer. In this respect, since my client ………. was the main buyer in the sale contract in question, the sale contract was made in collusion.
5- It has become necessary to file this lawsuit for the nullity of the collusive contract made between the defendants ……….. and ………., and to determine that my client ……. is the actual buyer in the sale contract in question.
LEGAL GROUNDS :
EVIDENCE : Tractor licence, receivable deed, expert, witness and all kinds of legal evidence when necessary.
CONCLUSION AND REQUEST : With the acceptance of our lawsuit for the above-mentioned reasons, first of all, we respectfully request and demand that the registration of the tractor in the registry be put into an injunction in order to prevent the transfer of the tractor in question to a third party, the cancellation of the collusive sale contract made between the defendants, the determination that the actual buyer of the sale contract is …….., and the decision to leave the judicial expenses and attorney fees on the defendants. ../../..
Plaintiff Attorney
Attorney…………………
(SIGNATURE)
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