TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : INCREASE IN EXPROPRIATION COMPENSATION
CASE VALUE :
EXPLANATIONS: 1-Our client’s ……. m2 plot of land registered in ……. Province, ……. District, ……. neighborhood, ……. block, ……. parcel, ……. was expropriated by the Municipality Council’s decision dated ……. and numbered ……. on the grounds that ……………….. would be built. Municipality.
2-The Appraisal Commission has determined the value of the immovable property to be ……. per m2 and has assigned a total expropriation value of ……. to our client’s land.
3-This amount was blocked by the defendant administration on behalf of our client on ……. ../../….
4-Our client’s plot of land was evaluated as if it were a field, and its value was kept very low. Our client’s plot of land faces the main road and is located within the city’s development area.
5-We request that the value determined by the commission be increased in line with current conditions and that the expropriation compensation for our client’s ……. m2 plot of land be increased to a total of ……. by determining it as ……. per m2.
LEGAL REASONS: Law No. 2942, HUMK
EVIDENCE: Title deed, expropriation documents, survey, expert examination, all kinds of legal and discretionary evidence.
RESPONSE PERIOD: 10 days
RESULT OF THE CLAIM: Based on the reasons stated, we request that the expropriation fee for our client’s ……. m2 plot of land be determined as ……. , that it be collected from the defendant together with the legal interest accruing from the date of expropriation, and that the costs of the proceedings be borne by the defendant. We request that the court rule that the opposing party’s attorney’s fees be awarded to us as attorneys in accordance with the final paragraph of Article 164 of the Attorney Act No. 1136, as amended by Act No. 4667.
PLAINTIFF’S ATTORNEY
