
……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : The request for cancellation of the decision dated …. and numbered …… regarding the expulsion from the membership of the association.
EXPLANATIONS :
1-Our client is one of the founding members of the defendant ……. association. Founded in 19…, he served as the founding chairman of the association and as a member of the board of directors and supervisory board at various times. During this period, he paid his dues regularly, participated fully in all activities of the association, and defended the aims and principles of the association everywhere.
2-Our client was expelled from the Association by the Board of Directors of the Association with the decision dated ……. and numbered ……. for “acting against the aims and principles of the Association and humiliating the moral personality of the Association”.
3-The decision is completely against the law. As explained above, our client has fulfilled his duties to the letter until today, considering associationism as a philosophy of life. The management of the association has expelled our client with the fire of revenge arising from the fact that our client clearly declared that he would not support them in the last general assembly election.
4-We request the cancellation of this decision taken by the association management.
LEGAL GROUNDS : CC, Association K.
EVIDENCE : Expulsion decision, dues receipts, decision book, witnesses
RESPONSE PERIOD : 10 days.
CONCLUSION OF THE REQUEST :
For the reasons explained above, we request the cancellation of the decision of the board of directors of the association, which was taken unjustly and removed our client from the membership of the association, the defendant to be charged with the costs of the proceedings, 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.
ATTORNEY FOR THE PLAINTIFF
……
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