TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :……. Association Board of Directors.
SUBJECT : Dissolution of the Association
EXPLANATIONS: 1-The Defendant, the ……. Association, is acting contrary to its founding purpose. Although the association was established as the …………. Neighborhood Beautification and Promotion Association, gambling is being conducted at its premises.
2-Our client is also a member of this association, number 116. He has served on the association’s management and supervisory boards at various times and has participated in association activities consistent with its founding purpose.
3-It is well-known that the individuals who have been part of the association’s management for the past two terms have not acted in accordance with the association’s founding purpose, have not addressed any issues concerning the neighborhood whose name the association bears, and have allowed gambling to take place at the association’s premises, located between houses in the neighborhood, until the early hours of the morning.
4-The situation has been reported to the police station several times, and police officers from the associations desk have closed the association’s premises for short periods of time.
5-We request the dissolution of the association because it does not serve its founding purpose and its administrators set a bad example for those around them.
LEGAL GROUNDS: Civil Code, Association Law, other legal provisions
EVIDENCE: Association Bylaws, witnesses
RESPONSE PERIOD: 10 days.
REQUESTED OUTCOME: Based on the stated reasons, we request a decision to dissolve the association, to impose litigation costs on the defendant, and to award attorney’s fees to us as attorneys in accordance with Article 164/final paragraph of the Lawyers’ Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY
