…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :……. Association Board of Directors.
SUBJECT :Dissolution of the ……. Association
EXPLANATIONS :1-The Defendant, the ……. Association, is acting contrary to its founding purpose. Although the association was established as the Association for Beautifying and Promoting the …………. neighborhood, gambling is being conducted at its premises.
2-Our client is also a member of this association, number 116. He has served on the association’s management and supervisory boards at various times and has participated in association activities in line with its founding purpose.
3-It is common knowledge that the individuals who have been in the association’s management for the last two terms have not acted in accordance with its founding purpose, have not dealt with any issues concerning the neighborhood whose name they bear, and have allowed gambling to take place until the early hours of the morning in the association’s premises located between houses in the neighborhood.
4-The situation has been reported to the police station several times, and police officers from the associations desk have closed the association’s premises for short periods.
5-We request the dissolution of the association because it does not serve its founding purpose and its administrators set a bad example for those around them.
LEGAL GROUNDS: Civil Code, Association Law, other legal provisions
EVIDENCE: Association Bylaws, witnesses
RESPONSE PERIOD: 10 days.
RESULT OF THE REQUEST: We request a decision to dissolve the Association for the reasons stated, to charge the defendant with the costs of the proceedings, and to award the opposing party’s attorney’s fees 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