TO THE PRESIDENCY;
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : …/…/… daily, …. published in the Official Gazette No.
made within the framework of the decision of the Council of Ministers No.
It is our request to cancel the urgent expropriation process.
DATE OF NOTIFICATION: …/…/…
DESCRIPTIONS :
1-) Our client owns … City, … District, … District, …. sheet, …. island, … parcel numbered immovable, …/…/… days, …. With the decision of the Council of Ministers published in the Official Gazette no.
2-) Article 27 of the Expropriation Law No. 2942; The cases in which urgent expropriation can be applied are listed one by one, and it is not possible to evaluate the expropriation process of our client’s real estate within the scope of the cases listed in the relevant article. For; Urgent expropriation is a method that can be applied exceptionally. Due to the decision of the Council of Ministers No. It has been reported that the Metropolitan Municipality has decided to expropriate it urgently.
3-) However, there are no conditions that require the implementation of the urgent expropriation procedure in the case, and therefore, the obligation to request the cancellation of the transaction from your Court has arisen.
LEGAL REASONS :
LEGAL EVIDENCE:
1-) … Province, … District, … District, … sheet, … island, … parcel numbered immovable land registry,
2-) The urgent expropriation decision of the Council of Ministers dated …/…/… and numbered …,
3-) Discovery and expert examination.
CONCLUSION AND REQUEST: Due to the reasons explained above, the cancellation of the urgent expropriation process carried out within the framework of the Council of Ministers decision dated …/…/… and numbered …, compensation for the loss of ….TL (to be increased according to the amount determined after the discovery and expert examination) and the burden of the trial expenses to the defendant. We request a decision by proxy. …/…/…
Plaintiff’s Attorney
Lawyer
ATTACHMENTS:
1-) … Province, … District, … District, … sheet, … island, … parcel numbered immovable land registry,
2-) The urgent expropriation decision of the Council of Ministers dated …/…/… and numbered …,
3-) One copy of approved power of attorney
