TO THE COURT OF FIRST INSTANCE
Plaintiff:
ATTORNEY:
DEFENDANT:
SUBJECT OF CASE: It is a pre-emption case. (….. TL)
EVENTS: 1- Plaintiff client, deed …. The island is the owner of 1/4 of the immovable registered in the parcel number of …….
2- One of the other stakeholders, ………….. sold its shares to the defendant on …./…./…… at a price of …… TL.
3- The plaintiff client wants to take his share from the defendant by using his preemptive right arising from the law. The sale price is deposited in the court cashier. In addition, other fees and taxes to be determined will be paid.
4- In order to prevent unavoidable consequences, we also request that a precautionary measure be placed on the relevant land registry until the end of the case.
For this reason, it was necessary to open this case.
LEGAL REASONS :
EVIDENCE: Land registry, witness statement and all kinds of legal evidence.
CONCLUSION AND REQUEST: According to the reasons presented above and the evidence shown, with the acceptance of the case, I request that the immovable share on the defendant be canceled in the title deed and registered in the name of the plaintiff, a precautionary measure to be taken in order to prevent the transfer to the land registry until the end of the lawsuit, and that the expenses and attorney’s fees be charged to the defendant.
I offer. Kind regards,
Plaintiff’s Attorney
Hunting………………….
(SIGNATURE)
ADDITIONAL:
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