(AUTHORISED TO HEAR THE CASE AS AN ARBITRATOR)
COURT OF FIRST INSTANCE
DEFENDANT : Republic of Turkey Ministry of Interior …… Provincial Directorate of Special Provincial Administration
DEFENDANT :
DEFENDANT : Republic of Turkey Ministry of Finance …….. Treasurer’s Office
SUBJECT OF THE LAWSUIT : ….. sy. Pursuant to Y., it consists of the request for the prevention of the intervention to the immovable property by your Honourable Judgeship as an arbitrator.
CASE VALUE : …… TL
FACTS : 1- The respondent administration has no interest or right in the property located in ………. …… square metres of land, which is located in ………., ….., …… parcel of the title deed and registered in the name of the client administration with …./…./…… date, ……. journal number, directly opposite the health institution called private hospital, in ………., in order to build a new ………. Defterdarlık building construction on it.
2- Neither the respondent administration nor the Ministry of Finance has any right on the immovable property in question. As a matter of fact, the defendant administration’s seizure of the land is completely unfair and unlawful, while the client administration has carried materials for the new Special Administration building to the land in question in accordance with the order …./…./…… date and ……… numbered order received from the Ministry of Interior to which it is affiliated.
3- In this respect, in order to remove the intervention of the defendant administration in the land, which it unjustly seized without any right, ….. sy. In accordance with the provisions of the law, it has become necessary to request your honourable court to examine this case for the prevention of seizure as an arbitrator.
LEGAL GROUNDS :
EVIDENCE : Title deed, witness statement, discovery and all kinds of evidence.
CONCLUSION AND REQUEST : With the acceptance of our lawsuit for the reasons stated above; the intervention made by the defendant administration to the immovable registered in the name of the client administration …… sy. I would like to request a decision to prevent the interference by the defendant administration to the immovable property registered in the name of the client administration as an arbitrator in accordance with the provisions of the Law No. and to leave the judicial expenses and attorney’s fee on the defendant administration.
I would like to request. Sincerely yours,
Plaintiff’s Counsel
Av………………….
(SIGNATURE)
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