COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
THE DEFENDANT :
SUBJECT OF THE CASE : Equalization lawsuit (…… TL).
FACTS : 1- The plaintiff client has a ‘certificate of insolvency’ for his receivable from the defendants ………..
2- The defendant inherited the debt upon the death of the defendant’s ancestor ……….. In addition, with the will dated …./…./…… made before the death of the muris, he willed the immovable property registered in the ……. island, ……… parcel number of the title deed to the other defendant ………. However, the value of this immovable is …………….. TL, which exceeds the savings quorum of the executor.
3- The debtor defendant has not filed a lawsuit for the annulment of this will despite being notified to file a lawsuit for the annulment of this will.
Therefore, it has become compulsory to file this equalization lawsuit.
LEGAL GROUNDS :
EVIDENCE : Certificate of incapacity to pay, certificate of inheritance, title deed, will, witness statement, expert examination and all kinds of legal evidence.
CONCLUSION AND REQUEST : According to the reasons and evidences presented above. I request that our lawsuit. Be accepted and the part of the will amounting to …… (……) TL, which encroaches on the reserved share. Be revoked and the costs and attorney fees be imposed on the defendants.
I would like to submit this request. Sincerely yours,
Counsel for the Plaintiff
Hunting………………….
(SIGNATURE)
ANNEX:
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