… TO THE PRESIDENT OF THE ADMINISTRATIVE COURT;
PLAINTIFF : TC No:
address :
attorney :
address :
DEFENDANT :
address :
SUBJECT : … Province, … District, … Neighborhood, …. die, …. ada, … regarding the expropriation of immovable property numbered parcel … /… /… daily, … numbered … Municipality -Council with the cancellation of the decision of the damage caused by the inability to use the immovable property during the expropriation process includes the request for compensation consists of the submission of our petition.
DATE OF NOTIFICATION : …/…/…
OUR EXPLANATIONS
1-) … Province, … District, … Neighborhood, …. plot, … name, … in relation to immovable parcel No. Municipal encumeni when …/…/… public interest in the history of the decision taken …/…/… 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 in the aftermath of the expropriation decision and the determination of the price of real estate of the defendant in court and the petition was filed on behalf of the administration for registration and attachments …/…/… in history has been communicated to our client.
2-) The immovable subject of the case remains within the limits of the authority of the Metropolitan Municipality … as of the location. … The protocol between the Metropolitan Municipality and the defendant … Municipality, which includes the transfer of authority to the defendant municipality, also lacks a legal basis. Dec. For this reason, there is a clear violation of the law in terms of the element of authority in the expropriation process carried out by the defendant … Municipality.
3-) On the other hand, during the execution of the expropriation process by the municipality, our client could not use the immovable and could not use it ….. TL damage was born.
4-) For the reasons explained, the cancellation of the expropriation transaction in question and the inability to use the immovable property …. it has been necessary to apply to your court to decide on compensation for the loss of TL.
LEGAL REASONS : 2709 P. K. m. 46; 2942 Pp. K. m. 14; 2577 Pp. K. m. 3, 32
LEGAL EVIDENCE :
1-) … Province, … District, … Neighborhood, … pafta, … island, … parcel numbered immovable title deed registration
2-) … The Municipal Council’s … / … / … daily, … numbered expropriation decision,
3-) Public interest decision made by the Municipal Council on the date of … /… /…,
4-)… The petition and October applications filed in the Civil Court of First Instance,
5-) … The protocol between the Metropolitan Municipality and the defendant … Municipality containing Decertification of authority to the defendant municipality,
6-) Discovery and expert examination.
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. …/…/…
ADDITIONAL:
Plaintiff Attorney
Lawyer.
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