Petition for the Recovery of Expropriation Compensation
TO THE HONORABLE COURT
…….
PLAINTIFF:…….
ATTORNEY:…….
DEFENDANT:…….
SUBJECT: Request for the return of expropriated real estate
EXPLANATIONS:
1-The plot of land belonging to our client, located at ……. Province, ……. District, ……. Neighborhood, ……. Block, ……. Parcel, ……. Address, with an area of ……. m2, was expropriated by ……. Municipality on ……. date on the grounds that ……………….. would be constructed.
2- The case filed by our party on ……. with file number……. For the increase of the expropriation compensation was concluded by the court’s decision dated……. And numbered……. The decision was also finalized in the appeal stage and became final upon notification to the parties on …….
3- Despite the passage of five years since the decision became final, the defendant administration has not carried out any work on the land in accordance with its justification.
4- We request the return of the property expropriated by the municipality on the grounds of …….. Our client is prepared to pay the. Municipality the amount paid to our client, along with legal interest.
LEGAL BASIS: Expropriation Law
EVIDENCE: Expropriation file, compensation increase lawsuit file, site inspection, expert examination, and all legal and discretionary evidence.
RESPONSE PERIOD: 10 days
CONCLUSION: For the reasons stated above, the defendant municipality expropriated a 1,136 m2 plot of land on ……. sheet, ……. parcel, with an area of 1,136 m², be returned to our client, that the litigation costs be borne by the defendant, and that the opposing party’s attorney’s fees be paid to us in accordance with the last paragraph of Article 164 of the Attorney’s Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY