CHAIRMAN OF THE ADMINISTRATIVE COURT,
The Execution is Requested to Stop.
prosecutor :
attorney :
DEFENDANT :
SUBJECT : ……. Of the municipality ………. it is related to our request for the cancellation of the dated …… Council decision.
THE DATE OF NOTIFICATION : ……….
INSTRUCTIONS
With our client …… signed between the administration …. with the contract ……. Of the municipality ………. dated …… which is the subject of Council decision no….. our client has purchased the business location in question at his address. The place of work in question has actually been handed over to our client. And still more our client continues his activity at the said workplace.
But, …. Of the municipality ………. according to the Council decision dated ……, a decision was made to demolish the place of work in question by betting that repairs and additions were made contrary to the project, but no renovations and additions were made at the place of work in question, as claimed.
Therefore, it is clear that the October decision mentioned above is contrary to the law, that is, the place of work is in accordance with the project, license and its annexes, as at the time of receipt.
Our client purchased the place of business subject to the lawsuit with a contract and then took over his real estate. As such, he continues his work-related activities at this workplace. As such, it is clear that the decision of the council to demolish the building will cause irreparable harm. Therefore, it is imperative that we request that the decision of the council be taken to stop the execution as a precautionary measure by the end of the case.
LEGAL REASONS: Zoning Law, Administrative Procedure Law and other legal legislation and case law
LEGAL EVIDENCE: …. dated contract, ….. The Municipality….. date …. Executive order No. 1, …. licenses, company records and all kinds of legal evidence
CLAIM AND CONCLUSION: For the reasons we have explained above, our rights to compensation and excess are reserved; in order to prevent irreparable damages, first of all, your measure is to stop execution, ….. The Municipality….. date …. we respectfully and bilvekale offer and request that the decision to cancel the numbered Council decision and to burden the defendant administration with the costs of the trial and the counter-power of attorney be made.
……/……/..…
Prosecutor
Attorney
ADDITIONAL:
1) Sample power of attorney,
2) ….. The Municipality….. date …. executive decision no.,
3) ….. agreement.
