COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : It consists of the request for reduction of the expropriation price.
FACTS : 1- The plaintiff administration wants to expropriate the immovable property numbered ……, block ……, parcel …….. in Yenimahalle District, all of which belongs to ………….., in order to build a children’s park.
2- The square metre of the immovable was determined by the valuation commission as ….. TL per square metre of the immovable. However, this is a very exorbitant price. The m2 prices of comparable immovables in the neighbourhood are on average …. TL.
3- The immovable, which is 350 m2 in total and valued at ….. The m2 price of the immovable, which is 350 m2 in total and valued at ….. TL and the expropriation price to be reduced to ……. TL.
For this reason, it has become compulsory to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Land registry, expropriation process, discovery, expert report and all kinds of evidence.
CONCLUSION AND REQUEST : According to the above-mentioned reasons and evidence, with the acceptance of our lawsuit, the expropriation price of the said immovable from ……. TL …… and that the costs of the proceedings and the attorney’s fee be charged to the other party.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
ATTORNEY………………….
(SIGNATURE)
ANNEX:
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