Petition For The Recovery Of Expropriation Compensation
…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT: …….
SUBJECT: Request for the return of expropriated immovable property.
EXPLANATIONS :1-Our client’s …… m2 plot of land, registered in ……. Province, ……. District, ……. neighborhood, ……. block, ……. parcel, ……. was expropriated by ……. Municipality on ……. on the grounds that ……………….. would be built.
2-The Action for Increase in Compensation filed by us on ……. with Case No. ……. on ……. to increase the expropriation compensation was concluded with the court’s decision dated ……. and numbered ……. The decision, which also passed the appeal stage, was notified to the parties on ……. and became final.
3-Despite the passage of 5 years since the decision became final, the defendant administration has not carried out any work on the land in accordance with its justification.
4-We request that the immovable property expropriated by the municipality on the grounds of …….. be returned to our client. Our client is prepared to pay the municipality the money paid to him by the municipality, together with the legal interest.
LEGAL GROUNDS: Expropriation Law
EVIDENCE: Expropriation file, compensation increase lawsuit file, discovery, expert examination, all types of legal and discretionary evidence.
RESPONSE PERIOD: 10 days
CONCLUSION: For the reasons stated above, we request that the defendant municipality return the ……. m2 plot of land, which was expropriated by the Defendant Municipality on ……. be returned to our client, that the costs of the proceedings be borne by 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