-SAMPLE PETITION-
SENTINEL ( ) TO THE COURT OF FIRST INSTANCE
AN INJUNCTION IS REQUESTED.
PLAINTIFF : A….. B….. (ID.:)
ADDRESS
ATTORNEY :
ADDRESS
DEFENDANT :C….. E….. (ID.:)
ADDRESS
CASE VALUE : 100.000,00 TL (ONE HUNDRED thousand Turkish LIRAS)
SUBJECT OF LITIGATION: The plaintiff requests that the client also have a ½ share, … Ada, … cancel the sale of shares of kain real estate on the parcel to the defendant and register it on my behalf for payment of the sale price.
INSTRUCTIONS
October 1 October, the plaintiff client has a ½ share in the Island, … kain Parcel (the title deed is presented in the appendix Annex-1), immovable, non-litigious E…. B…. By 03.04.2021 with a price of 100.000,00 TL the defendant is C….. E….. it was sold to and transferred in the deed.
The plaintiff client was not informed about the transfer process in question, no information was provided to him through a Notary Public channel, and there was an obligation to open this case within the 2-year limitation period specified in the law.
The subject of the lawsuit is real estate of a field nature, out of the case E…. B…. And the plaintiff is left from the client’s father, due to the fact that the plaintiff has shared ownership of the client, as well as 732, 733 and 734 of the Turkish Civil Code.according to the articles, there is a legal right to pre-purchase. For this reason, the plaintiff C…. the defendant without informing the client. E….. we request that the transfer to be cancelled provided that the transaction fee is stored by us at the Court teller and registered on the plaintiff client, and during this case it will be decided to write an invoice to the Elmadag Land Registry Office to take measures to prevent the transfer of the said share to a third party in order to prevent the transfer of the said share to a third party.
LEGAL REASONS: TMK, TBK, HMK and other relevant legislation
EVIDENCE : Land registry records, witness statements, precedent price research, discovery, oath, expert report, etc. all delail
CONCLUSION AND CLAIM : With all the reasons described above and re’ you will be considered by your court:
-Firstly, it is decided to accept our request for an injunction in order to prevent the transfer of the real estate subject to litigation to a third party and to write to the land registry office for this matter to the client
-The decision to cancel the title deed registration on the defendant and register it on the plaintiff’s client is made on the basis of the fact that the real estate subject to the lawsuit will be stored in the Court teller for payment of the sale price of the real estate and fees and expenses of the defendant by us
-Any kind of trial will be held and we will request by proxy that the estimate of the power of attorney be decided by the other party. 03.08.2021
Plaintiff A….. B….. Attorney
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