… TO THE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE;
PLAINTIFF: TC No:
ADDRESS:
REPRESENTATIVE:
ADDRESS:
DEFENDANTS:
ADDRESS:
SUBJECT: Submission of our petition requesting the determination of possession.
VALUE OF THE CLAIM:
OUR EXPLANATIONS
1-) Our client, …. …., has been using the immovable property located next to his field, registered under parcel number … in … village, … district, … province, and for which there is no title deed, for agricultural activities for … years. During the cadastral survey conducted on …/…/…, the immovable property that our client uses for agricultural activities was mistakenly registered in the names of … …. and …. ….
2) It is established by the statements of these individuals, who appear as possessors and whose names are registered, that they do not actually possess the property.
3) The on-site inspection and expert examination to be conducted by your court at the location of the property in question, and the witness statements that we will present during the hearings if deemed appropriate by your court, will explain the situation with complete clarity.
3) It has become necessary to apply to your court for the cancellation of the erroneous registration and the determination of possession.
LEGAL GROUNDS: Law No. 3402, Article 12; Law No. 4721, Articles 981, 982, 983, 984; Law No. 6100, Article… 240, 266, 288
LEGAL EVIDENCE: 1. Cadastral survey report dated …/…/… 2. Statement transcripts 3. Witness list showing the names and addresses of the witnesses and the subjects they will testify about.
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request, on behalf of our client, that the cadastral survey dated …/…/… be annulled, that possession be determined in the name of our client, and that the court costs and attorney’s fees be borne by the opposing party. …/…/…
ATTACHMENTS:
Plaintiff’s Attorney
Attorney
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