TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : Our Request for an Increase of ………-TL in the Easement Fee
EXPLANATIONS: 1-Our client is the owner of a property registered in the land registry with an area of …… m2, located in ……. Province, ……. District, ……. Neighborhood, ……. Location, Plot No: ……., Block No: ……., Parcel No: …….
2-The defendant institution has established an easement right on a portion of our client’s real estate measuring ……. m2 and has assessed an easement fee of ……..-TL.
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 real estate has negatively affected the value of the real estate and caused a loss in value. The difference between the property’s value before the energy transmission line was installed and its current value is much higher than the assessed easement fee. There are olive trees on the property, and the energy transmission line will negatively affect the crop and reduce its yield, causing our client to suffer losses. Moreover, this property is located within the municipal boundary and is classified as land.
4-For these reasons, it has become necessary to file this lawsuit to increase the easement fee assessed by the defendant institution from ………..-TL to ………-TL by ……..-TL.
LEGAL REASONS: Expropriation Law, Relevant Legislation
EVIDENCE:
Land Registry Records,
Expropriation Documents,
Survey and Expert Examination,
Legal and Discretionary Other Evidence, etc.
RESPONSE PERIOD: 10 days
REQUESTED OUTCOME: For the reasons stated above, the defendant institution’s assessment of the easement fee of ……… -TL compensation amount to be increased by …….-TL to ……..-TL, for the litigation costs to be borne by the defendant, and for the opposing party’s attorney’s fees to be awarded to us as attorneys in accordance with the final paragraph of Article 164 of the Attorney Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY
