……. TO THE PRESIDENCY
REQUEST FOR STAY OF EXECUTION
THE PLANTIFF :…….
ATTORNEY :…….
DEFENDANT : MINISTRY OF PUBLIC WORKS AND HOUSING GENERAL DIRECTORATE OF DISASTER WORKS
SUBJECT : The request for the cancellation of the determination dated ……. regarding the heavy damage caused by the earthquake and the stay of execution.
EXPLANATIONS : 1-In the earthquake that occurred on 17/08/99, the immovable property at ……., where my clients’ workplace is located, was damaged.
2-In the determination made by the defendant to determine the damage on ……., it was determined that the building was heavily damaged and had to be demolished.
3-After the determination made about the building, we had a determination made by İ.T.Ü. lecturer Civil Engineer …… …….. and in the report dated 30/11/99 given by the expert, it was stated that the building was damaged but it was possible to repair the damage.
4-According to the report given by the expert, it is clear that there is no need to demolish the building belonging to my clients, since it is technically possible to eliminate the damage to the building. For this reason, we apply to your court with the request for the cancellation of the determination dated ……. given by the defendant and for a stay of execution until the case is concluded.
LEGAL GROUNDS : MK., LAW, AND RELATED LEGISLATION
EVIDENCE : ……./…../…….. REPORT DATED ../../…. AND OTHER EVIDENCE.
RESPONSE PERIOD : 30 Days
CONCLUSION OF THE REQUEST : Based on the above reasons, we request the cancellation of the defendant’s determination dated ……. that the building belonging to my clients has suffered heavy damage as a result of the earthquake and should be demolished, the stay of execution until the case is concluded, the judicial expenses to be charged to the defendant, and the counterparty attorney fee to be decided on our behalf as a lawyer in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
PLAINTIFFS’ COUNSEL
…….
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