TO THE COURT OF FIRST INSTANCE

prosecutor :

TC IDENTIFICATION NUMBER :

address :

attorney :

(Legal representatives of the parties, if any)

address :

(Legal representatives of the parties, if any)

DEFENDANT :

ADDRESS :

SUBJECT : It Consists of a Request for the Return of Expropriated Real Estate Due to Misuse.

INSTRUCTIONS :

1-) The subject of the lawsuit is registered on behalf of the client in the real estate deed No. 52 island 5 parcel, while the General Directorate of Foundations is registered on behalf of the Council of Foundations dated (ANNEX-1) B….. His brother C…. A…. f…. from the Foundation. n…. C…. A…. (P….) in order to fully reveal the appearance of the madrasa, to prevent damage from the environment and to restore the structure to its original state in its historical environment, it was nationalized in order to rebuild and restore the environmental buildings in accordance with the original.

2-) The difference in the price determined by the client in the price increase case (ANNEX-2) filed against the defendant administration and finalized on the date of /…// The difference is still in the uhd of the defendant administration.

3-) immovable …/…/… respondent with the finalization of the administrative de facto expropriation in the history of the price of the hand …/…/… for the purpose of the no operation within five years of the date of the expropriation and do not have the facilities, real estate generate income by renting it out while leaving intact the land the building in the bottom floor of a barber shop as filed with the spouse of the client that uses it against prompt, adequate payment (Appendix 3) and the second floor of a tourism company is also currently has under the lease.

4-) Article 23 of the Expropriation Law No. 2942. item “within five years from the date of finalisation of the price of expropriation, nationalization by the administration in accordance with the fourth paragraph of Article 22, or the transfer or allocation made by the administration; or the installation is not performed for the purpose of expropriation and transfer or any operation are allocated to the benefit of the public and thus a demand for immovable property is left as it is if the owner of the goods by paying with legal interest from the day they receive compensation or heirs to process its immovable property and take it back. it contains the provision “. The circumstances contained in the article took place in the event that is the subject of the lawsuit.

5-) For the reasons we have explained, it was necessary to file a lawsuit to ensure that the real estate is registered in the title deed on behalf of the client with the cancellation of the title deed registration of the real estate in question on behalf of the administration in accordance with the procedures and principles set out in the law.

LEGAL REASONS : 2942 P. K. m. 23.

LEGAL EVIDENCE : 1-) The decision of the Assembly of Foundations of the General Directorate of Foundations dated …/…/…

2-) …/…/… the price increase case file that has been finalized on

3-) A lawsuit filed against the client’s spouse with an ecrimisil request

4-) Expert Review

5-) Exploration

CONCLUSION AND REQUEST: For the reasons we explained above, the TL stipulated in the price increase case has not been collected from the defendant administration, this amount has been excluded from the calculation, with the refund of the initially paid to the client, together with the legal interest from the payment date, the defendant, the real estate subject to the case has been taken back from the defendant administration, the cancellation of the land registry and the re-registration on behalf of the client; we respectfully request on behalf of our client that the amount to be found as a result of the calculation to be made be decided on the deduction of the court costs incurred by the client initially and the income received by the defendant administration outside the purpose of expropriation and, accordingly, the determination of the amount, the trial costs and the attorney’s fee to be charged to the counterparty. …/ …/ …

ANNEXES : 1-) The decision of the Assembly of Foundations of the General Directorate of Foundations dated October /… /

2-) …/…/… the price increase case file that has been finalized on

3-) A lawsuit filed against the client’s spouse with an ecrimisil request