Petition For The Cancellation Of The Decision To Expel From Association Membership
…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT:…….
SUBJECT: Request for 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 fully in all activities of the association, 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 aims 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 a way of life and has fulfilled his duties to the letter to this day. The association management expelled our client out of a desire for revenge stemming from his clear declaration that he would not support them in the last general assembly election.
4-We request the cancellation of this decision taken by the association management.
LEGAL GROUNDS: Civil Code, Association Law.
EVIDENCE: Expulsion decision, membership fee receipts, decision book, witnesses.
RESPONSE PERIOD: 10 days.
RESULT OF THE REQUEST: Based on the reasons stated above, we request the annulment of the association management board decision dated and numbered above, which unjustly expelled our client from association membership, the imposition of the costs of the proceedings 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