……. TO THE HONOURABLE JUDGE
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our request for the repurchase of the expropriated immovable property.
EXPLANATIONS :1-Our client’s ……. Province, ……. District of ……………….., ……. neighbourhood, ……. block, ……. plot, ……. parcel, ….. m2 land registered in ……. parcel was expropriated by ……. Municipality on ……. on the grounds that ……………….. would be built.
2-In order to increase the expropriation price from our side, ……. on ……. on ……. date ……. The Tezyidi Fee Lawsuit filed with ……. date and ……. The decision was finalised with the decision of the court dated ……. and numbered ……. and the decision, which also passed through the appeal stage, was finalised by notifying the parties on ……..
3-Although 5 years have passed since the finalisation of the decision, the defendant administration has not carried out any work on the land in accordance with its justification.
4-We request that the immovable property expropriated by the municipality on the grounds of …….. be returned to our client. Our client is ready to pay the money paid to our client by the municipality to the municipality with legal interest.
LEGAL GROUNDS : Expropriation Law
EVIDENCE : Expropriation file, price increase case file, 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 land of ….. m2 registered in ……. island, ……. plot, ……. parcel, ……. plot, ……. parcel belonging to our client, which was expropriated by the Defendant Municipality on ……., be decided to be returned to our client, 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
…….
You can access our other article examples and petition examples by clicking here.