COURT OF FIRST INSTANCE
PLAINTIFF: …………… University Rectorate
REPRESENTATIVE:
DEFENDANT:
SUBJECT OF THE CASE: Land registration case.
FACTS: 1- The immovable property registered under parcel number …… in cadastre …… was expropriated pursuant to the expropriation decision approved by the Rectorate of ………….. University with its decision dated …./…./…… and numbered …………, and within the framework of the provisions of Law No. ……….
2- The expropriation compensation has been deposited into account number ………. at the …….. Branch of ………….. Bank in the name of the defendant and is submitted as an attachment.
3- Although the expropriation decision was served on the defendant through a notary public on …./…./……, the defendant has not appealed the expropriation proceedings to the judicial or administrative courts and has not yet completed the transfer procedures at the land registry on behalf of my client.
It has become necessary to file this lawsuit in order for the aforementioned immovable property to be registered in the name of the plaintiff administration.
LEGAL GROUNDS:
EVIDENCE: Expropriation documents, bank receipt, survey, etc.
CONCLUSION AND REQUEST: Based on the reasons stated above and the evidence presented, I request that our case be accepted and that, in accordance with … sy. Y., a decision be made to register the aforementioned immovable property in the name of the plaintiff administration and to charge the defendant with the costs of the proceedings and the attorney’s fees.
I hereby submit. Yours sincerely,
Plaintiff’s Attorney
Attorney………………….
(SIGNATURE)
ATTACHMENT: