CHAIRMAN OF THE ADMINISTRATIVE COURT,
It is Being Demanded that the Execution Be Stopped.
prosecutor :
lawyer :
THE DEFENDANT :
SUBJECT : ……. The Municipality ………. it is related to our request for the cancellation of the dated …… Parliamentary decision.
DATE OF NOTIFICATION : ……….
instructions
Our client …… administration …… signed …… Dated …… belongs to the municipality …… With the contract …… Subject to the decision of the Municipal Council,. Which is the number at our client purchased the business in question. The workplace in question has actually been transferred to our client. Moreover, our client continues to operate at the workplace in question.
However, according to the decision of the Municipal Council dated …… Belonging to the municipality, it was decided to demolish the workplace in question, claiming that repairs and additions were made contrary to the project, but no renovations and additions were made at the workplace in question, as claimed.
October October decision mentioned above is therefore contrary to the law, that is, it is clear that the workplace is in compliance with the project, license and annexes on the date of receipt.
Our client purchased the workplace subject to the lawsuit by contract and then took over the real estate. In this way, he continues his activity at work. Therefore, it is clear that the council’s decision to demolish the building will lead to irreparable damages. Therefore, it is imperative that we request that the council take a decision to stop the execution as a precautionary measure until the end of the case.
LEGAL REASONS: Zoning Law, Administrative Procedure Law and other legal regulations and case law
LEGAL EVIDENCE:
…. the dated contract, ….. The municipality….. dated…. Executive Decree No. 1, …. licenses, company records and all kinds of legal evidence
CLAIM AND CONCLUSION: Our rights to compensation and exemption are reserved for the reasons explained above; first of all, to take measures to stop the execution in order to prevent irreparable damages, ….. The municipality ….. History…. We respectfully request and request that it be decided to cancel the numbered Assembly decision and to charge the trial expenses and the counter power of attorney to the defendant administration.
……/……/..…
Prosecutor
Lawyer
in addition:
1) Example of Power of Attorney,
2) ….. The municipality….. history…. executive order no.,
3) ….. his deal.