Petition for a Lawsuit for Excessive Exploitation (Gabin)

TO THE DUTY PRIMARY CIVIL COURT
OF ISTANBUL

PLAINTIFF: Name and Surname (Turkish Republic Identity Number: …)
Address: …

ATTORNEY: Lawyer's Name and Surname,
Address: …

DEFENDANT: Name and Surname
Address: …

SUBJECT: Gabin case

VALUE OF THE CLAIM: … Turkish Lira.

EXPLANATIONS:

1. My client has been living abroad for many years. He contacted ... Real Estate to sell his single-story house with a private garden located in ... area. The real estate agent told him that the house and garden were neglected, wouldn't fetch much money, and that finding a buyer would be difficult. He also stated that my client was unaware of real estate prices in Türkiye, and purchased the house for a price far below its actual value, ... Turkish Lira. This transaction was carried out by exploiting my client's lack of information and trust.
2. My client's knowledge of this matter came to light while dining at a famous restaurant in the area. The restaurateur stated that this area is favored by the wealthy and that houses with gardens sell for more than in the city. Furthermore, he learned a few days earlier that a house had been put up for sale by ... Real Estate for ... Turkish Lira. Following this deception, my client felt compelled to file this lawsuit to recover the property from the defendant, who purchased it at a very low price.

EVIDENCE:

1. Determination of comparable sales prices (a request will be made to the land registry office for the sales table of neighboring parcels)
2. Expert examination
3. Discovery
4. Witness testimonies and other legal evidence

WITNESSES:

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

LEGAL GROUNDS: Turkish Code of Obligations, Article 28 and related legislation.

CONCLUSION AND REQUEST: For the reasons explained above, I respectfully request and demand that the court accept the case and, firstly, order a precautionary measure to be placed on the title deed to prevent the transfer of the property to third parties, to annul the sale made due to usury and to register it in the title deed, and to order the defendant to bear the court costs and attorney's fees.

…/…/…

Plaintiff's
Attorney's Name and
Surname