TO THE CIVIL COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Establishment of right of way.
FACTS : 1- The plaintiff client is engaged in farming. My client bought a field … months ago. There is a distance of ….. meters between the field he bought and the road. The field between this distance belongs to the defendant. My client has to pass through the defendant’s field in order to use his immovable property.
2- The person from whom my client purchased the field has actually used it for many years to cross the defendant’s field. However, the defendant did not provide the same opportunity for my client. In order to prevent my client from crossing the field, he fenced the field with wire. The plaintiff has to go around … Km. to cover the distance of ….. meters between the road and the field.
3- For the ….. meter wide road to be established ….. TL compensation for the meter wide road to be installed.
For these reasons, it has become necessary to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Title deed records, witnesses, discovery, expert witnesses and all kinds of evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, I request that our lawsuit be accepted and the right of way be established in favor of the plaintiff on the immovable property belonging to the defendant in return for compensation.
I would like to submit this request. Sincerely yours,
Counsel for the Plaintiff
Hunting………………….
(SIGNATURE)
ANNEX):
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