……. TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our Request for Increase of the Easement Fee ………-TL.
EXPLANATIONS :1-Our client ……. Province, ……. District, ……. Neighbourhood, ……. Location, Pafta No: ……., Island No: ……., Parcel No: ……., registered to the title deed ….. m2 is the owner of the immovable.
2-The right of easement has been established by the defendant institution on the ……. m2 part of our client’s immovable property and ……..-TL easement fee has been appraised.
3-The easement fee assessed by the Defendant Institution is very low. The establishment of the easement right and the passage of the Energy Transmission Line over the immovable has negatively affected the value of the immovable and caused a loss of value. The difference between the value of the immovable before the passage of the energy line and the current value is much higher than the easement price. There are olive trees on the immovable property and the passing energy transmission line will adversely affect the crop and reduce the yield and will cause the victimisation of our client. This immovable is already in the municipality’s neighbourhood area and has the qualification of land.
4-For these reasons, it has become necessary to file this lawsuit in order to increase the easement fee of ………..-TL, appraised by the defendant Institution, to ………-TL with an increase of ……..-TL.
LEGAL GROUNDS : Expropriation Law, Related Legislation
EVIDENCE :
Land Registry Records,
Expropriation Documents
Exploration and expert examination
Other Legal and Discretionary Evidence etc.
RESPONSE TIME : 10 days
CONCLUSION OF THE REQUEST : For the reasons stated above, we request that the easement price of ………-TL, which was assessed by the defendant institution, be increased to ……..-TL with an increase of …….-TL, that the costs of the proceedings be charged to the defendant, and that the counterparty attorney fee be awarded 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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