TO THE COURT OF FIRST INSTANCE
MEASURE IS DEMANDED
Plaintiff:
ATTORNEY:
DEFENDANT:
SUBJECT : About the cancellation of the construction contract.
EXPENSE BASIS
VALUE: ………. TL (When the actual value is revealed by the expert, in case of an increase in value, on the condition that the fee related to the surplus is paid by us)
EXPLANATION
1- The client …….. his sons …….. and ……… with the participation of the defendant on the date of ………, “immovable sales promise in the form of arrangement and construction contract in return for flat”, according to the content of the contract;
“… -………., …………Mah. ………. The usufruct right belonging to ………… in the immovable registered in the island, parcel 1, will be removed by making a title deed application by ………… for 3 days at the latest, since the construction contract has been made by the notary public of ………… on ………….
-The debt related to the lien placed by the Tax Office on the above immovable by the tax debt of ………… will be paid by ………..
-………………. ……… TL was paid to the land owners by the The content of the contract has been created.
Again, in the annex section of the contract, “… From the delivery of the immovable to the contractor ………. and their children will be paid rent until the flat is delivered. The rental price will not be more than …….. TL…” was noted.
2- Upon the contract made , this time, the parties will agree, this time, with the participation of my client and his children, with the date of the ……… Notary Public of ……… has been signed.
3 – In the future, my client’s son …… ……. It is understood that he sold it for TL and my client suffered damage in this context.
4- First of all, since the right of usufruct on the real estate in question belongs to my client ………., it is obvious that the disposition of ……….. without my client’s knowledge and consent will not have legal validity.
5- A warning was issued on the date of .. My client, again, by keeping his good will and distracting the contractor himself, has stalled by saying that I will deliver tomorrow, and unfortunately, at the point reached, the defendant has not fulfilled his acquisitions in return for the contract in any way. understood that he saw. When the client ……….. went to the relevant land registry office, he had a great shock.
When the relevant documents submitted to your court are observed, my client has suffered a great deal, so it has become necessary to open this case.
RESULT AND REQUEST
1-CANCELLATION of the contract, which is the subject of the agreement, especially because the defendant has not fulfilled his obligations,
2- IMPLEMENTING MEASURES on the construction subject to the action registered on the defendant, by writing to the relevant land registry office, if any, considering the possibility that the construction built on the land registered in the current title deed may have been transferred to others,
3-Reserving our material and moral compensation rights,
4- Upon the acceptance of our case, I wish that the court costs and attorney’s fees be taken from the defendant.
I offer. Kind regards,
Plaintiff.
Deputy