…….. Presidency;

PLAINTIFF :

TC IDENTIFICATION NUMBER :

ADDRESS :

Deputy :

(Legal representatives of the parties, if any)

ADDRESS :

(Legal representatives of the parties, if any)

DEFENDANT :

ADDRESS :

Subject: … / … / … daily,…. published in the Official Gazette numbered

… numbered … made in accordance with the decision of the Council of Ministers

it is our request to cancel the hasty expropriation process.

DATE OF COMMUNIQUE : …/…/…

INSTRUCTIONS :

1 -) our client owns … province, … district, … District,…. die, …. island, … parcel-numbered real estate, … / … / … daily, …. according to the decision of the Council of Ministers published in the Official Gazette … numbered … it was decided to nationalize it in a hurry.

2 -) 27 of the expropriation law No. 2942. in the article, the cases in which hasty expropriation can be applied are counted individually, and it is not possible to evaluate the expropriation process performed in our client’s real estate within the scope of the cases listed in the relevant article. Because; the state of hasty expropriation is an exceptional method that can be applied, the property subject to the lawsuit….. in the scale zoning plan, it remains on a 25-meter road and therefore …. due to the decision of the Council of Ministers to remain on the road in the zoning plan …. It was reported that the Metropolitan Municipality decided to nationalize it in a hurry.

3 -) however, there are no conditions in the case that require the application of the hasty expropriation procedure, and therefore there is an obligation to ask your court to cancel the transaction.

Legal reasons: 2942 P. K. m. 3, 27, 32

LEGAL EVIDENCE :

1 -) … province, … district, … District, … pafta, … island, … parcel numbered real estate title registration,

2 -) Council of Ministers … / … / … day, … numbered hasty expropriation decision,

3 -) discovery and expert examination.

Conclusion and request : for the reasons explained above, …/…/… day, … cancellation of the hasty expropriation process made in accordance with the decision of the Council of Ministers ve….TL in compensation for damages (to be increased according to the amount determined after discovery and expert examination), we demand by proxy that the trial costs be decided to be charged to the defendant. …/…/…

Acting Plaintiff

Lawyer

ECLAIR:

1 -) … province, … district, … District, … pafta, … island, … parcel numbered real estate title registration,

2 -) Council of Ministers … / … / … day, … numbered hasty expropriation decision,

3 -) one sample of approved power of attorney