Appeal Against Decision To Expel From Cooperative Partnership
TO THE CIVIL COMMERCIAL COURT
Application for Provisional Measures.
Plaintiff: A. ………
Defendant: B. ……… (Cooperative Representative)
Subject: Request for the annulment of the Cooperative General Assembly’s decision no. ……… dated …….. and for a provisional measure to be granted to ensure the continuation of my membership until the conclusion of the case.
Legal Evidence: 1. Cooperative Articles of Association, Cooperative General Assembly Decision, Cooperative Accounting Records, Expert Examination, and all other relevant legal evidence.
Legal Grounds: Article 16 of Law No. 1163, Civil Code, Turkish Commercial Code, and other relevant legislation.
Explanations:
I am a member of Cooperative B ……… with membership number ……………
The Cooperative’s Board of Directors, without any valid reason (on the grounds that I failed to pay my dues), decided to expel me from membership with its decision dated ………. and the decision was served to me on ………..
My objection to this decision, submitted to the cooperative’s general assembly, was rejected by the decision dated ……… and numbered ………….
I received this decision on …………. Since the general assembly’s decision is unfounded, it has become necessary to appeal to the honorable Court.
Request and Conclusion: I respectfully request the annulment of the decision dated ……… and numbered ………, which approved the decision of the cooperative general assembly dated ……….. and numbered ……….. to expel me from the cooperative, the imposition of provisional measures to ensure the continuation of my membership until the conclusion of this case, and the imposition of costs on the defendant. ………./……/……..
Plaintiff A………….