……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :……. Association Board of Directors.
SUBJECT :……. Association’s dissolution
EXPLANATIONS :
1-Defendant ……. Association acts against the purpose of establishment. Although the association was established as the Association for the Beautification and Promotion of the …………. neighbourhood, gambling is played in the clubhouse.
2-Our client is also a member of this association number 116. He has taken part in the management and supervisory boards of this association at various times. He has carried out association activities in accordance with the purpose of establishment.
3-It is known to everyone that the persons who have come to the management of the association for the last two terms have not acted in accordance with the purpose of establishment, have not dealt with any problems of the neighbourhood they bear the name of, and have been gambling until the morning in the clubhouse of the association located between the houses in the neighbourhood.
4-The situation was reported to the police station several times. The police officers from the associations desk closed the clubhouse for short periods of time.
5-We request the dissolution of the association since the association does not serve the purpose of its establishment and its executives set a bad example to their surroundings.
LEGAL GROUNDS : Civil Code, Law on Associations, other articles of law
EVIDENCE : Association Statute, witnesses
RESPONSE PERIOD : 10 days.
CONCLUSION OF THE REQUEST : For the reasons explained, we request that the Association be dissolved. That the costs of the proceedings be charged to the defendant. That the counterparty’s attorney fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Law No. 1136 on Attorneyship Law amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
…….
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