8.1 PROPERTY DIVISION LAWSUIT PETITION

A request for interim injunction is submitted to the BAKIRKÖY FAMILY COURT.

PLAINTIFF: Hayriye Ekinci (Turkish National Identity Number: 111111111)
Zümrüt neighborhood, Yakut street, No: 11/11

REPRESENTATIVE: Attorney Sabahat Yılmaz – UETS

DEFENDANT: Ali Rıza Ekinci

REPRESENTATIVE: Attorney Leyla Pamir

SUBJECT: Pursuant to Article 231 of the Turkish Civil Code, this is a request for the division of assets acquired during the marriage, reserving our rights to claim further amounts, for the collection of said receivables from the defendant, and for a precautionary measure to be placed on the immovable property registered in the defendant's name and used as a residence, as indicated in the attached document

EXPLANATIONS

1) THE REAL ESTATE ACQUIRED WITHIN THE MARRIAGE
WAS DISPOSED OF IN BAD FAITH. HALF THE VALUE OF THE HOUSE MUST BE PAID TO THE PLAINTIFF.

The plaintiff and the defendant were married in 2003. During their marriage, the plaintiff worked, and together they purchased a house in Bakirköy district of Istanbul. However, due to incompatibility, the defendant sold the house one day after the plaintiff filed for divorce in Bakirköy Family Court (case number 2030/88) with the intention of concealing assets. The value of the house should be determined by an expert, and the defendant, who sold the house in bad faith, should pay half of its value.

2) REGARDING THE PROPERTY LOCATED IN SARIYER DISTRICT OF ISTANBUL, THERE IS A PARTICIPATION CLAIM IN FAVOR OF MY CLIENT WITHIN THE SCOPE OF THE LIQUIDATION OF THE PROPERTY REGIME.

Furthermore, a property located at Kuyucu Mah. Vera Sok. No:15/2 in Sarıyer district of Istanbul was purchased during the marriage, and it is evident that half of its value will belong to my client due to the liquidation of the marital property regime. The value of the property should be determined by an expert appointed by your esteemed court, and half of this value is the amount that the defendant must pay. The request for a preliminary injunction is related to the marital property liquidation case being heard in the Bakırköy Family Court under file number 2030/88 , and pursuant to Article 390/1 of the Code of Civil Procedure, the request must be evaluated by your esteemed court.

3) THE DEFENDANT HAS MADE VARIOUS ATTEMPTS TO AVOID PAYING THE AFOREMENTIONED DEBTS.

Since the property regime will be liquidated upon the finalization of the divorce decree, the defendant spouse's
hasty sale of the immovable property registered in their name just one day after the divorce proceedings were initiated
demonstrates bad faith. To prevent the concealment of assets,
we request that a precautionary measure be placed on the registration of the said immovable property.
Consequently, as explained above, it has become necessary to file this lawsuit seeking a decision on the liquidation of the property regime due to divorce and the
division of assets according to the community property regime
.

LEGAL GROUNDS:
Turkish Civil Code, Turkish Code of Civil Procedure, and all relevant legislation.

EVIDENCE
• Bakirköy 452nd Family Court, Case No. 2030/88,
• Population registration certificate
• Marriage certificate/marriage records
• Land registry records (relating to immovable properties)
• Records to be requested from the Land Registry Office
• Expert examination
• On-site
Witness statements
• Bank records, account statements
• Official documents related to sales transactions
• Court case files (divorce case and property regime liquidation files)
• Social Security Institution records/employment and income documents
• Notary records
• Enforcement files (if any)
• Correspondence, message records (HTS, WhatsApp, etc. – provided they are legally compliant)
• Oath
• All kinds of legal evidence

CONCLUSION AND REQUEST:
For the reasons explained above;

1)
that a precautionary measure be placed on the immovable property located at the registered address specified in the defendant's name, primarily to prevent irreparable harm;
2) We request that our lawsuit be accepted and that half of the assets acquired as a result of the division of property be
taken from the defendant and paid to our client, the plaintiff, reserving our rights to claim further damages;
3) We request that the court costs and attorney's fees be borne by the defendant
.

Plaintiff's attorney,
Sabahat Yılmaz