COURT OF FIRST INSTANCE
DEFENDANT :
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : Equalisation lawsuit (…… TL).
FACTS : 1- The plaintiff client has a ‘certificate of insolvency’ for the receivable from the defendants ………..
2- The defendant inherited the debt with 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 property is …………….. TL and exceeds the savings quorum of the deceased.
3- Although the debtor defendant has been notified to file a lawsuit for the cancellation of this will, he has not filed a lawsuit for equalisation.
Therefore, it has become compulsory to file this equalisation 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 that the part of the will amounting to …… (……) TL, which encroaches on the reserved share, be cancelled and that the costs and attorney fees be imposed on the defendants.
I would like to submit my request. Sincerely yours,
Plaintiff’s Counsel
Av………………….
(SIGNATURE)
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