… TO THE PRESIDENT OF THE ADMINISTRATIVE COURT;
Prosecutor:
TURKISH IDENTITY NUMBER :
address :
lawyer:
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
suspect:
address :
SUBJECT : … Province, … County, … County, … pafta, …. …/…/… Consists of the cancellation of the decision of the Municipal Council …/…/… on the expropriation of the immovable property numbered … date, ada parcel and the request for compensation for the damage caused by the inability to use the immovable property during the expropriation process.
NOTIFICATION DATE: …/…/…
descriptions :
1-) … Province, … District, … District, …. October Oct. 1), a public interest decision (Oct.2) was taken by the Municipal Council on the date of …parcel, … island, … parcel numbered (ANNEX-1) parcel, and …/…/… on the dates of …/…/… and …/…/… the client registrant was invited to negotiate, upon the refusal of our client … /…/… date and … numbered (Annex-3) expropriation decision of the Municipal Council … /…/… a lawsuit was filed in the Civil Court of First Instance on behalf of the defendant administration for the determination and registration of the value of the real estate. October October The petition and its annexes (Annex-4) have been notified to our client on the date of …/…/…………..
2-) The immovable property subject to the lawsuit is under the jurisdiction of the Metropolitan Municipality as of its location. Oct Dec… The protocol (Annex-5) containing the transfer of authority between the Metropolitan Municipality and the respondent … Municipality to the respondent municipality also lacks legal basis. Therefore, the expropriation process carried out by the defendant … Municipality is unlawful in terms of the element of authority.
3-) On the other hand, our client could not use the real estate during the expropriation process carried out by the municipality and due to the inability to use ….. TL has suffered damage.
4-) For the reasons explained above, there has been an obligation to apply to your court for the cancellation of the said expropriation transaction and the decision on compensation for the TL damage caused by the inability to use the real estate ….
LEGAL REASONS: 2709 SK m. 46; 2942 SKm 14; 2577 SKm 3,
32
LEGAL EVIDENCE:
1-) … Province, … District, … Neighborhood, … pafta, … island, … parcel numbered immovable land registry
2-) … The decision of the Municipal Council to expropriate …/…/… date and … number,
3-) The public interest decision made by the Municipal Council about …/…/…,
4-)… The petition and Octobers of the case filed in the Court of First Instance,
5-) … The protocol between the Metropolitan Municipality and the respondent … Municipality Decrees the transfer of the authority to the respondent municipality,
6-) Exploration and expert examination.
CONCLUSION AND CLAIM: For the reasons described above, we request that the decision of the municipal council numbered … Province, … District, … Neighborhood, … pafta, … island, … expropriation of the parcel numbered … /…/… be annulled and …. compensation for the loss of TL be decided, that the Court be decided to charge the trial expenses to the defendant to be increased according to the amount to be determined as a result of the discovery and expert examination. …/…/…
eclair:
1-) … Province, … District, … District, … parcel, … island, … land registry of real estate with parcel number
2-) … The decision of the Municipal Council to expropriate …/…/… date and … number,
3-) The public interest decision made by the Municipal Council about …/…/…,
4-)… The petition and Octobers of the case filed in the Court of First Instance,
5-) … The protocol between the Metropolitan Municipality and the respondent … Municipality Decrees the transfer of the authority to the respondent municipality,
6-) A sample of the approved power of attorney.
The Plaintiff’s Lawyer
Hunting.