TO THE HONORABLE COURT
…….
PLAINTIFF:…….
ATTORNEYS:…….
DEFENDANT:…….
SUBJECT: INCREASE IN EXPROPRIATION COMPENSATION
CASE VALUE:
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 the Municipal Council’s decision dated ……. and numbered ……. on the grounds that ……………….. would be constructed on it.
2-The Appraisal Commission determined the value per square meter of the property as……. And allocated a total expropriation compensation of ……. to our client’s land.
3-This amount was blocked by the defendant administration on behalf of our client on ……. ../../….
4-Our client’s land was evaluated as if it were a field and its value was kept very low. Our client’s land faces the main road and is located within the city’s development area.
5-We request that the value determined by the commission be increased in accordance with current conditions and that the expropriation compensation for our client’s……. M2 plot of land be set at ……. per m2, bringing the total amount to …….
LEGAL GROUNDS: Law No. 2942, HUMK
EVIDENCE: Title deed, expropriation documents, survey, expert examination, all legal and discretionary evidence.
RESPONSE PERIOD: 10 days
OUTCOME OF THE CASE: For the reasons stated above, we request that the expropriation compensation for our client’s ……. m2 plot of land be determined as ……. and collected from the defendant together with the legal interest accruing from the date of expropriation, and that the defendant bear the costs of the proceedings. We request that the court decide that the opposing party’s attorney’s fees be awarded to us as a retainer in accordance with the last paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY