CHAIRMANSHIP OF THE ADMINISTRATIVE COURT,

It Is Demanding To Stop The Execution.

PLAINTIFF :

Acting :

DEFENDANT :

Subject:……. Of the municipality ………. the cancellation of the council’s decision …… dated is related to our request.

THE DATE OF NOTIFICATION : ……….

INSTRUCTIONS

Signed between our client and his administration…. with the contract ……. Of the municipality ………. dated …… numbered are subject to the decision of the committee …. our client bought the place of business in question at his address. The workplace in question has actually been handed over to our client. And our client is still operating at the workplace in question.
But, …. Of the municipality ………. dated …… contrary to the decision of the committee numbered project with demolition and renovations in the work place the additional bet has been made the decision in question has been taken, however, as there are no any additions and renovations in question was allegedly in the workplace.
Therefore, it is clear that the decision of the council mentioned above is against the law, that is, the work place is in compliance with the project, license and annexes as at the time of delivery.
Our client purchased the business subject of the lawsuit under contract and subsequently took over his possession. As such, he continues his work-related activities at this work place. Of course, it is clear that the council’s decision to demolish it will cause irreparable damage. Therefore, until the end of the case, it is necessary that we request that the council’s decision be made to stop the execution as a precautionary measure.
Legal reasons : Zoning Law, Administrative Procedure Law and other legal legislation and case law

LEGAL EVIDENCE : …. dated contract, ….. The municipality of ….. date …. numbered Council decision, …. license, company records and all kinds of legal evidence

Claim and conclusion: for the reasons explained above, without prejudice to our rights regarding compensation and excess, we have decided to stop the execution in order to prevent irreparable damages ….. The municipality of ….. date …. we respectfully supply and demand the cancellation of the numbered Council decision and the decision to install the power of attorney against the defendant administration with the costs of the trial.

……/……/..…

Plaintiff