…….TO THE PRESIDENCY
REQUEST FOR SUSPENSION OF EXECUTION
…….
PLAINTIFFS :…….
THEIR ATTORNEYS :…….
DEFENDANT: MINISTRY OF PUBLIC WORKS AND HOUSING, GENERAL DIRECTORATE OF DISASTER MANAGEMENT
SUBJECT: Request for suspension of execution with the cancellation of the finding dated ……. regarding the severe damage caused by the earthquake.
EXPLANATIONS : 1-The property located at ……. address, where my clients’ workplace is located, was damaged in the earthquake that occurred on 17/08/99.
2-In the determination made by the defendant on ……. to determine the damage that occurred, it was determined that the building was severely damaged and needed to be demolished.
3-After the inspection of the building, we had an inspection carried out by …… …….., a lecturer at ITU and a Senior Civil Engineer, and the report dated 30/11/99 issued by the expert stated that the building was damaged but that it was possible to repair the damage.
4-According to the report issued by the expert witness, since it is technically possible to repair the damage to the building, it is clear that there is no need to demolish the building belonging to my clients. For this reason, we apply to your court with the request that the determination dated ……. issued by the defendant be canceled and that the execution be suspended until the case is concluded.
LEGAL GROUNDS: MK., İYUK, AND RELEVANT LEGISLATION
EVIDENCE: ……./…../…….. DATED FINDINGS REPORT, REPORT ISSUED BY THE EXPERT ON ../../…. AND OTHER EVIDENCE.
RESPONSE PERIOD: 30 days
CONCLUSION: Based on the above reasons, we request that the defendant’s finding dated ……. regarding the severe damage caused by the earthquake to the building belonging to my clients and the necessity of its demolition be annulled, that the execution be suspended until the conclusion of the case, that the court costs be borne by the defendant, We request 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.
PLAINTIFFS’ ATTORNEY