Petition for Interim Measures

…TO THE PRIMARY CIVIL COURT

ISTANBUL

INTERIM INJUNCTION

PLAINTIFFS MAKING THE REQUEST:

1. Name and Surname – (Turkish Republic Identity Number: …) – Address
2. Name and Surname – (Turkish Republic Identity Number: …) – Address

ATTORNEY: Lawyer's Name and Surname – Address

DEFENDANTS:

1. Name and Surname – Address
2. Name and Surname – Address

SUBJECT: The lawsuit concerns a request for an interim injunction to prevent the defendants from harvesting the produce of the properties in question and from cutting down the trees.

EXPLANATIONS:

1. In the case before our court, the details of which and hearing date are stated above, the court ruled in favor of the plaintiffs, and this decision was appealed by the defendants. The Court of Cassation upheld the decision to accept the plaintiffs' claims, but reversed the ruling regarding legal fees. Accordingly, the Court of Cassation upheld the decision to annul the fraudulent sale, but the court has not yet issued a final decision.
2. The defendants are harvesting the produce from the properties in question, which the Supreme Court has deemed fraudulent, and are unjustly profiting from the sale. A large portion of the properties are hazelnut orchards, and it is currently hazelnut harvest season. According to our information, they plan to harvest the hazelnuts themselves until the hearing date, and then cut down all the hazelnut trees and sell the wood before the court decision. This demonstrates their intention to obtain through illegal means what they cannot obtain legally.
3. The defendants' unlawful actions will both violate our clients' rights and cause a decrease in the economic value of the properties in question. A preliminary injunction to prevent the harvesting of hazelnut crops and the cutting down of trees is essential for both protecting our clients' rights and achieving a just outcome. In light of the evidence presented to the court, a preliminary injunction is necessary to preserve the current state of the properties and prevent further damage.

EVIDENCE:

1. Land registry records,
2. ... Civil Court of First Instance, case file number .../..
3. Relevant reports and photographs regarding the current state of hazelnut orchards,
4. Written and oral statements obtained regarding the defendants' planned actions,
5. Other legal evidence.

LEGAL GROUNDS: Turkish Code of Civil Procedure No. 6100, Articles 389 et seq., and other relevant legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request that our request be granted and that a preliminary injunction be issued to prevent the defendants from harvesting the crops on the property in question and from cutting down the trees.

…/…/…
Plaintiffs'
Attorney Name and Surname
Signature