TO THE HONORABLE COURT
…….
PLAINTIFF:…….
ATTORNEYS:…….
DEFENDANT:…….
SUBJECT: Our Request for an Increase of ………-TL in the Easement Fee
EXPLANATIONS:
1-Our client is the owner of the property located at ……. Province, ……. District, ……. Neighborhood, ……. Location, ……. Parcel No: ……., ……. Block No: ……., ……. Parcel No: ……. address, registered in the land registry with an area of …… m2.
2-The Defendant Institution has established a right of easement on a portion of our client’s immovable property measuring ……. m2 and has assessed an easement fee of …….. TL.
3-The easement fee determined by the defendant institution is quite low. The establishment of the easement right and the passage of the Energy Transmission Line over the real estate has negatively affected the value of the real estate and caused a loss in value. The difference between the property’s value before the energy transmission line was installed and its current value is much higher than the assessed easement fee. There are olive trees on the property, and the energy transmission line will negatively affect the crop and reduce its yield, causing our client to suffer losses. Additionally, this property is located within municipal boundaries and is classified as agricultural land.
4-For these reasons, it has become necessary to file this lawsuit to increase the easement right fee determined by the defendant institution from ………..-TL to ………..-TL by ………..-TL.
LEGAL GROUNDS: Expropriation Law, Relevant Legislation
EVIDENCE:
Land Registry Records,
Expropriation Documents,
Survey and Expert Examination,
Legal and Discretionary Other Evidence, etc.
RESPONSE TIME: 10 days
DESIRED OUTCOME: For the reasons stated above, the defendant institution’s assessment of the easement fee of …… -TL compensation amount to be increased by …….-TL to ……..-TL, litigation costs to be borne by the defendant, and the opposing party’s attorney’s fees to be paid to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Act No. 4667,
PLAINTIFF’S ATTORNEY