Petition For Increase In Expropriation Compensation
…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : INCREASE IN EXPROPRIATION COMPENSATION
VALUE OF THE CLAIM:
EXPLANATIONS :1-Our client’s ……. m2 plot of land registered in ……. district, ……. neighborhood, ……. block, ……. parcel, ……. Municipality.
2-The Appraisal Commission determined the value of the immovable property to be ……. per m2 and 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 farmland, 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 set at ……. per m2, bringing the total expropriation compensation for our client’s ……. m2 plot to …….
LEGAL GROUNDS: Law No. 2942, HUMK
EVIDENCE: Title deed, expropriation documents, survey, expert examination, all types of legal and discretionary evidence.
RESPONSE PERIOD: 10 days
RESULT OF THE CLAIM: For the reasons stated, the expropriation compensation for our client’s ……. m2 plot of land is determined to be ……. , to be collected from the defendant with legal interest accruing from the date of expropriation, and the costs of the proceedings are to be borne by the defendant. Pursuant to the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667, we request that the opposing party’s attorney’s fees be awarded to us as attorneys.
PLAINTIFF’S ATTORNEY