
… TO THE NIGHT FAMILY COURT
PRELIMINARY INJUNCTION IS REQUESTED.
PLANTIFF :X.… TO THE NIGHT FAMILY COURT
PRELIMINARY INJUNCTION IS REQUESTED.
PLANTIFF :X.Y. (TCKN)REQUESTED.
PLANTIFF TO THE NIGHT FAMILY COURT
PRELIMINARY INJUNCTION IS REQUESTED.
PLANTIFF :X.Y. (TCKN)
ADDRESS :Example MAh. Example Street. Example Apartment 1/1 Batıkent/ANKARA
AGENT :ATT.
ADDRESS :…
DEFENDANT :Z.T. (TCKN)
address :
THE CASE :Liquidation of the Property Regime
SUBJECT: It is the presentation of our petition regarding the Requests for contribution share, Value increase share and Participation Fee.
A O I K L A M A L A Rhe presentation of our petition regarding the Requests for contribution share, Value increase share anUBJECT: It is the presentation of our petition regarding the Requests for contribution share, Value increase share and Participation Fee.
A O I K L A M A L A R
The parties got married on 1.1.1982 and there is a divorce case between them that is being heard by the … Family Court … Since the divorce case was filed on Dec. 20.01.2020, the goods between the date of marriage and the date of filing the divorce case are the subject of the property regime’s requests for liquidation.
The parties did not make any property regime agreement when they got married and in the following years.he parties did not make any property regime agreement when they got married and in the following years. Since their marriage covers the periods before and after the applicable Turkish Civil Code, the property regime to be applied must be determined in accordance with Article 202/1 and Article 10/1 of the Code of Practice of the Turkish Civil Code.
Therefore, the separation of goods regime applies to goods between Dec. 1.1.1982 and 31.12.2001, and for goods between Dec. 1.1.2001 and Dec. 20.01.2021, when the divorce case was filed, the accession regime applies to acquired goods.efore, the separation of goods regime applies to goods between Dec. 1.1.1982 and 31.12.2001, and for goods between Dec. 1.1.2001 and Dec. 20.01.2021, when the divorce case was filed, the accession regime applies to acquired goods. In this context, weherefore, the separation of goods regime applies to goods between Dec. 1.1.1982 and 31.12.2001, and for goods between Dec. 1.1.2001 and Dec. 20.01.2021, when the divorce case was filed, the accession regime applies to acquired goods. In this context, we concretize our claims for receivables as follows:
1- Although the defendant party owns a shop that he purchased in 1981 in his own name, we do not have any claim regarding this shop because it was acquired before the marriage union. However… there is a request that this store at his address will receive participation from the rental income deposited in his bank.
2-On the other hand, in the deed purchased on behalf of the defendant again in 1997 by selling and using the plaintiff’s trappings …. there is a contribution fee to be received on the registered apartment.-On the other hand, in the deed purchased on behalf of the defendant again in 1997 by selling and using the plaintiff’s trappings …. there is a contribution fee to be received on the registered apartment.
3-Since the plaintiff contributed to the land acquired o-On the other hand, in the deed purchased on behalf of the defendant again in 1997 by selling and using the plaintiff’s trappings …. there is a contribution fee to be received on the registered apartment.
3-Since the plaintiff contributed to the land acquired on behalf of the defendant in 2008 and registered as … in the title deed with 50,000 TL he received from his father, there is a request that he will receive an increase in value due to the existing land. Dec.
4-There is a request that he will receive 50 percent participation on the vehicle with license plates acquired in 2018, when the regime of participation in goods acquired in the marriage union is valid and registered in the name of the defendant.
EVIDENCE : Population Family Registration Table, Land Registry and Traffic Registration Records, Witness
LEGAL REASON :TMK M.227, M.236, M.EVIDENCE : Population Family Registration Table, Land Registry and Traffic Registration Records, Witness
LEGAL REASON :TMK M.227, M.236, M.239 and relevant EVIDENCE : Population Family Registration Table, Land Registry and Traffic Registration Records, Witness
LEGAL REASON :TMK M.227, M.236, M.239 and relevant legislation
CONCLUSION OF THE REQUEST: For the reasons explained above,
The parties’ property regime will be liquidated in accordance with Articleby evaluating the opportunity provided by 107, the right to request and sue for excess is reserved with the registration,
1-On behalf of the defendant … for the rental income deposited to his bank, he will receive 1000 TL participation for now,
2-For the flat registered in the title deed as … in the name of the defendant, he will receive a contribution share of 10,000 TL for now,
3-For the land registered in the title deed as … in the name of the defendant, he will receive a contribution share of 20,000For the flat registered in the title deed as … in the name of the defendant, he will receive a contribution share of 10,000 TL for now,
3-For the land registered in the title deed as … in the name of the defendant, he will receive a contribution share of 20,000 TL for now,
4-It was decided that 10.000 TL will be received for participation for the vehicle with license plate registered in the name of the defendant for the time being and given to the plaintiff,
5-Since he will receive a contribution share, interest will be applied from the date of the case, from the date of the decision for other receivables,
6-The immovables subject to the case are concrete and the claims for receivables are determined, in accordance with the decisions of the Court of Cassation on all immovables and vehicles 3.we request that a decision be made to apply an injunction to prevent the sale and transfer to persons.to the c6-The immovables subject to the case are concrete and the claims for receivables are determined, in accordance with the decisions of the Court of Cassation on all immovables and vehicles 3.we request that