TO THE CHAIRMANSHIP OF THE ADMINISTRATIVE COURT;
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
address :
SUBJECT : … Province, … District, … Neighborhood, …. die, …. the name of the expropriated immovable parcel No. … relating to …/…/… blog, … … numbered Municipality-the decision of the committee with the cancellation of the real estate during the process of expropriation compensation for loss due to the failure to use the prompt is from.
DATE OF NOTIFICATION : …/…/…
INSTRUCTIONS :
1-) … Province, … District, … Neighborhood, …. plot, … name, … immovable parcel No. (Appendix 1) for the municipal encumeni when …/…/… public interest in the history of the decision (Annex-2) received …/…/… and …/…/… in the days maliki have been invited to negotiate the client’s record, when he didn’t respond to our client’s invitation encumeni of Municipal… … / … / … blog, … numbered expropriation decision (Annex-3) afterwards, the determination of the price of the immovable and the defendant in court and the petition was filed on behalf of the administration for registration and the annexes (Annex-4) …/…/… in history has been communicated to our client.
2-) As of the immovable place subject to litigation … it remains within the jurisdiction of the Metropolitan Municipality. … The protocol (ANNEX-5), which includes the transfer of authority between the Metropolitan Municipality and the respondent Municipality to the respondent municipality, also lacks dec legal basis. For this reason, the expropriation process carried out by the defendant Municipality is against the law in terms of the element of authority.
3-) On the other hand, during the execution of the expropriation process by the municipality, our client could not use the real estate and was born from the inability to use it ….. There has been a loss of TL.
4-) For the reasons described, it was necessary to apply to your court to cancel the expropriation process and decide on compensation for the loss of ….TL arising from the inability to use the real estate.
LEGAL REASONS : 2709 P. K. m. 46; 2942 P. K. m. 14; 2577 P. K. m. 3,
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LEGAL EVIDENCE :
1-) … Province, … District, … Neighborhood, … pafta, … island, … land registry of immovable land with parcel number
2-) … The decision of the Municipal Council … /… /… on the expropriation of the day, … numbered,
3-) A public interest decision on the date of /… /… issued by the Municipal Council,
4-)… October petition and attachments filed at the Court of First Instance,
5-) … Protocol between the Metropolitan Municipality and the respondent … Municipality dec the transfer of authority to the respondent municipality,
6-) Discovery and expert review.
Results and PROMPT : for the reasons we have explained above, provinces, counties, and neighborhoods, plot, … name, … expropriated immovable parcel No. relating to …/…/… blog, … and the cancellation of the decision of the committee numbered municipal….Tl the compensation of damage (increased by the amount of discovery and examination of expert witnesses to be determined after the court decided to request from the court to the defendant of costs and expenses that we will be yukletilm. …/…/…
ECLAIR:
1-) … Province, … District, … Neighborhood, …. pafta, … ada, … land registry of immovable land with parcel number
2-) … The decision of the Municipal Council … /… /… on the expropriation of the day, … numbered,
3-) A public interest decision on the date of /… /… issued by the Municipal Council,
4-)… October petition and attachments filed at the Court of First Instance,
5-) … Protocol between the Metropolitan Municipality and the respondent … Municipality dec the transfer of authority to the respondent municipality,
6-)An example of a certified power of attorney.
Plaintiff Attorney
