COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
THE DEFENDANT : ……….. Municipality Presidency
SUBJECT OF LAWSUIT : ……. Sy. The lawsuit consists of the request for cancellation and registration of the title deed pursuant to Art.
FACTS : 1- The defendant administration expropriated. The immovable property belonging to my client. Located in the location of ……… with the title deed ……, ………. parcel number ………, with the decision dated …./…./…… and numbered ……………..
2- The purpose of the administration in expropriating. The said property was to build a children’s park. However, although five years have passed, the administration. Has not carried out any work in this direction, as well as unknown people and stray cats and dogs roam here at night and pose a danger. To the children and health of the neighborhood.
3- Although my client is ready to pay the money received as expropriation fee, the defendant administration does not want to return the immovable to my client.
For the above-mentioned reasons. It has become necessary to file this lawsuit for the return of the immovable to my client.
LEGAL GROUNDS :
EVIDENCE : Land registry, expropriation documents, discovery, expert report and all kinds of evidence.
CONCLUSION AND REQUEST : With the acceptance of the lawsuit according. To the reasons and evidence presented above, ….. sy. I request that the lawsuit be accepted and the said immovable property. Be taken back from the defendant administration. The title deed be canceled and registered in the name of the plaintiff, and the judicial expenses and attorney’s fee be imposed on the defendant.
I would like to submit my request. Sincerely yours,
Counsel for the Plaintiff
Hunting………………….
(SIGNATURE)
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