……. TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
DEFENDANTS :…….
DEFENDANT :…….
SUBJECT : INCREASE OF THE EXPROPRIATION PRICE
CASE VALUE :
EXPLANATIONS :1-Our client’s ……. Province, ……. ……. district, ……. neighbourhood, ……. block, ……. plot, ……. parcel, ….. m2 land of our client ……. was expropriated by ……. Municipality according to the decision of the Municipality Council dated ……. and numbered ……. on the grounds that ……………….. will be built.
2-The Appraisal Commission determined the value of the m2 of the immovable as ……. and a total expropriation value of ……. was assigned to our client’s land.
3-This price was paid by the defendant administration on behalf of our client ……. …/…/…. on behalf of our client.
4-Our client’s land was evaluated as a field and its value remained very low. Our client’s land fronts the main road and is within the development area of the city.
5-We request that the value determined by the Commission be increased in accordance with the conditions of the day and that the expropriation price for our client’s ……. m2 land be increased to a total of ……. by determining it as ……. for m2.
LEGAL GROUNDS : Law No. 2942, Code of Civil Procedure
EVIDENCE : Land registry, expropriation documents, discovery, expert examination, all kinds of legal and discretionary evidence.
RESPONSE TIME : 10 days
CONCLUSION OF THE REQUEST : For the reasons explained, we request that the expropriation price for our client’s land of ……. m2 be determined as ……., to be collected from the defendant together with the legal interest to be accrued from the date of expropriation, to charge the defendant with the costs of the proceedings, and to award the counterparty attorney fee 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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