Application For Real Estate Registration With Extraordinary Statute Of Limitations
…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT: 1-) Treasury, represented by the Property Directorate
2-)……Village Legal Entity
SUBJECT: Our request for registration due to extraordinary statute of limitations.
VALUE OF THE CLAIM: …….
EXPLANATIONS :1-Our client has been using a field located in the ………….. area of …………. village continuously for over 30 years as the owner. The real estate is located completely outside the village, at the foot of Mount Murat and on the edge of a dry riverbed known as the old stream.
2-No private or legal entity or the Treasury has any rights over the real estate in question.
3-We request the registration of this real estate in the land registry on behalf of our client, who has been using this field as the owner in good faith and without interruption for more than 30 years.
LEGAL GROUNDS: MK.m.639 and other articles of law.
EVIDENCE: Witnesses, discovery, and all types of legal and discretionary evidence.
RESPONSE PERIOD: 10 days.
RESULT OF THE REQUEST: For the reasons stated, we request that our case be accepted, that the real estate in question be registered in the Land Registry in the name of our client, that the litigation costs be borne by the opposing party, and that the opposing party’s attorney’s fees be awarded to us as attorneys, in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY