…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our request for intervention and compensation.
EXPLANATIONS :1-The defendant owns a plot of land adjacent to our client’s plot of land, which is registered in the land registry as ……. Province, ……. District, ……. Village, ……. Block, ……. Parcel, measuring …. m2.
2-The defendant, who has established a factory producing construction machinery on his plot, has encroached on approximately 100 m² of our client’s plot.
3-Our client had the necessary measurements taken and warned the defendant with a notice dated ……. and numbered ……. by the ……. Notary Public.
4-The defendant did not even respond to our client. Our client’s good faith efforts were also unsuccessful.
5-We request that the defendant’s unjust encroachment on our client’s land be prevented and that compensation be paid for the land.
LEGAL GROUNDS: MK.m.618 and other provisions.
EVIDENCE: Title deed, discovery, expert examination, witness statements.
RESPONSE PERIOD: 10 days.
RESULT OF THE CLAIM: For the reasons stated, to prevent the unlawful encroachment by the defendant on the real estate belonging to our client, to demolish the building on the land, to order the defendant to pay our client, who has been unable to use the 100 m2 portion of the land for the 18 months since the building was constructed, a total of ……. plus legal interest accruing from the date of the lawsuit, and that the defendant be ordered to pay the costs of the proceedings. We request 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