TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT: …….
SUBJECT: Request for the annulment of the decision dated … and numbered … regarding expulsion from association membership.
EXPLANATIONS: 1-Our client is one of the founding members of the defendant ……. association. He served as the founding president of the association, which was established in 19.., and as a member of the management and supervisory boards at various times. During this period, he paid his dues regularly, participated in all the association’s activities without exception, and defended the association’s aims and principles everywhere.
2-Our client was expelled from the association by the Association Management Board with the decision dated ……. and numbered ……. on the grounds of “acting contrary to the association’s objectives and principles and demeaning the association’s moral character.”
3-The decision is completely contrary to the law. As explained above, our client has considered association membership to be his way of life and has fulfilled his duties to the letter until today. The association management expelled our client out of revenge for his clear declaration that he would not support them in the last general assembly election.
4-We request that this decision taken by the association management be revoked.
LEGAL REASONS: MK, Association K.
EVIDENCE : Expulsion decision, membership fee receipts, decision book, witness
RESPONSE PERIOD : 10 days.
REQUESTED OUTCOME: Based on the reasons stated above, we request the revocation of the association management board’s decision dated and numbered as above, which unjustly expelled our client from association membership, and the imposition of litigation costs on the defendant. and that the opposing party’s attorney’s fees be awarded to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY
