Application for Determination of Cooperative Membership

TO THE DUTY PRIMARY COMMERCIAL COURT

ANKARA

PLAINTIFF:
Name and Surname – (Turkish Republic Identity Number: …) – Address

ATTORNEY:
Lawyer's Name and Surname – Address

DEFENDANT:
Name and Surname – Address

SUBJECT OF THE CASE:
Determination of cooperative membership and annulment of the decision to expel a member.

EXPLANATIONS:

1. My client of the SS … Housing Construction Cooperative by the decision dated …/…/… and numbered …. During his membership, my client paid a total of … Turkish Lira in dues to the cooperative, and the cooperative provided my client with a document stating that all dues up to …/…/… have been paid in full. This document demonstrates the soundness of my client's relationship with the cooperative.
2. However, on …/…/… the cooperative, in a notice sent to my client, terminated his membership in an irregular and unfounded manner due to existing legal disputes between my client and the third party through whom he was included in the cooperative via share transfer. number 52. This decision is contrary to the cooperative's internal regulations and the Turkish Commercial Code, and violates my client's rights.
3. My client's cooperative membership has been unfairly terminated in a way that prevents him from exercising the rights he initially possessed. This decision by the cooperative is unlawful and extremely detrimental to my client's interests. Therefore, it has become necessary to file a lawsuit to annul this decision and to have the membership reinstated.

EVIDENCE:

1. Decision of SS … Housing Construction Cooperative dated …/…/… and numbered …
2. Payment receipts
3. Pink slip
4. Termination decision
5. Cooperative records
6. Other legal evidence

LEGAL GROUNDS:

Turkish Commercial Code (TTK), Turkish Code of Obligations (TBK), Code of Civil Procedure (HMK), and other relevant legislation.

CONCLUSION AND REQUEST:

For the reasons briefly explained above, I respectfully request and demand that the court accept the case, annul the decision of SS… Housing Construction Cooperative to expel my client from membership, which is contrary to procedure and law, confirm my client's membership in the cooperative, and, if these requests are not accepted, order the defendant cooperative to pay the … TL membership fee paid by my client to the cooperative, together with legal interest accruing from the date of payment, and leave the court costs and attorney's fees to be borne by the defendant.

…/…/…
Plaintiff's
Attorney Name and Surname
Signature