TO THE JUDICIARY OF THE COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : Enmity consists of presenting our objections.
CASE VALUE:
(On property rights cases)
DESCRIPTIONS :
1-) Our client … by the plaintiff ……. Against the Presidency of the Irrigation Union, with the allegation that the products were damaged due to the explosion of the irrigation pipes. Court of … E. …. A lawsuit for pecuniary damages was filed with the file numbered K. (ANNEX 1)
2-) However, the ownership of irrigation pipes belongs to DSI and our client irrigation union is only responsible for operation and maintenance.
3-) Therefore, the case should be filed against the owner of the property, DSI, our client does not have any hostility in the relevant case and the case should be dismissed due to the absence of hostility.
4-) In addition, damages arising from the defect in the construction, use or protection of a public facility; Since it is in the nature of damages arising from administrative decisions and actions, it constitutes the subject of a full remedy action, and cases of this nature should be brought in the administrative jurisdiction.
LEGAL REASONS :
LEGAL EVIDENCE:
one-) …. Court of … E. ….K. file no.
CONCLUSION AND REQUEST: For the reasons we have explained above, we submit and demand that our hostility objection be accepted and the case dismissed without examining the merits of the dispute about our client, that the litigation expenses and attorney’s fee be charged to the other party, and that a decision be made by proxy on behalf of our client. …/ …/ …
ATTACHMENTS:
one-) …. Court of … E. ….K. file no.
2-) One copy of approved power of attorney.
Attorney for the Defendant
Lawyer
