Below is a final draft of the Lawsuit Retainer and associated questions. This is a class action that IS NOT LINKED to any other lawsuit currently being undertaken by the GC’s. It’s a totally separate lawsuit. Please read through it carefully and feel free to ask questions or comment. No query is to big or too small as you have to be 100% happy with the decision that you make
We have had a UK Legal Eagle look at the paperwork and the retainer has been amended and added to in many areas since the first one was received. The retainer has been kept as short and as simple as possible but should you have any queries Athan at the Tsimpedes Law Firm are happy to answer any questions that you may have either by email or phone as are we.
or us and we will ask the question for you
When you are happy with joining this proposed lawsuit simply let us know as soon as possible and we will sent you a printable copy via a Word Doc, on Tsimpedes Headed paper. When we have the numbers needed to go forward we will then put the wheels in motion to get the lawsuit underway. We hope this will be sooner rather than later.
The Tsimpedes Law firm will contact you direct regarding the $300 returnable retainer fee. We suggest any documentation you wish to provide to is sent via DHL to Tsimpedes in Washington, (ie. parceltogo.com) as this is secure, quick and relatively low cost. Those of you in the TRNC who cannot rely on the North Cyprus post, we can print off anything you send us and mail it on your behalf.
In conclusion, we cannot guarantee this will be a success, but after the last six years of being ignored, scammed, lied to and pushed from pillar to post this looks to be our best avenue of approach so far and we as ABAG are prepared to give it a chance especially after the Orams losses.
Please pass these details on to ANYONE you feel may benefit from such an action NOT JUST AGA VICTIMS
Kindest Regards
Aga Buyers Action Group
RETAINER AGREEMENT
I, __________________, hereinafter referred to as the Client, agrees the TSIMPEDES LAW FIRM (hereinafter “FIRM”), shall represent the Client in connection with recouping monies paid towards a fraudulent property scheme by the TRNC, Republic of Turkey and other parties to be filed in the Washington, DC USA under the following conditions:
[1] SCOPE OF REPRESENTATION
The FIRM shall represent the Client only for the purposes mentioned above including filing suit and litigation at the trial court level only. This representation does not include any appeals that may be required. However, if an appeal is requested by the Client, The Tsimpedes Law Firm will appeal the case for the amount of $2,500 excluding the costs of transcripts or court fees necessary that the Client agrees to pay from the gross recovery. Client agrees this matter may be filed as a class action or joined with others in a lawsuit who have similar claims (as defrauded buyers of TRNC property) and shall fully cooperate with the FIRM at all times.
[2] COMPENSATION
Under this contingent fee agreement, the Client shall pay the FIRM compensation as follows:
1. An administrative fee (non expense) in the amount of THREE HUNDRED DOLLARS ($300.00); The low fee contemplates that hundreds will participate to make this lawsuit viable to pursue. Should there not be a substantial number joining in this lawsuit that makes it impractical to file the lawsuit, the Tsimpedes Law Firm will either refund your $300.00 or allow you other legal options to pursue at your discretion.
2. Contingency. Client agrees to pay the FIRM attorney fees on a contingency basis as follows: TWENTY-FIVE (25%) of the gross recovery, judgment, settlement, award or other value received (the amount recovered prior to any expenses incurred by the FIRM being deducted) obtained for the client in any recovery, award, judgment, settlement or other value received (collectively referred to as the “recovery”).
[3] EXPENSES AND COSTS.
The Client shall be liable for expenses and attorney’s fees only to the extent of any recovery made and if there is no recovery, then the Client shall not be responsible for the payment of any expenses and attorney’s fee whatsoever. Such specific costs for which the Client may be charged, include, but are not limited to, the following: long distance telephone calls, local and out of town transportation, out of town food and lodging, messenger deliveries, overnight mail, multiple photocopies, transcription fees, agency assessed fees, specialized research materials, expert fees and the like.
The Client agrees and understand that he/she is participating in a lawsuit with other AGA Buyer Group members or other defrauded buyers of Property in the TRNC who have been fraudulently induced by the TRNC of their money and will share in the costs and expenses on a pro rata basis. This also requires Client to share evidence and discovery with each other in such cases only. Unless indicated herein, The Firm will not disclose any information to third parties (other than buyers of TRNC property who have filed lawsuits by the Tsimpedes Law Firm) unless the client provides permission or has provided such information in the public domain.
If the FIRM obtains a settlement offer which the client rejects, then, should the Client settle on his/her own or retain other counsel and achieve a settlement or win a verdict, the FIRM shall be entitled to the same fee as had the client accepted the earlier settlement offer obtained by the FIRM.
Client agrees and understands this he/she does not seek title to property in the north of Cyprus but only the return of the monies paid or other compensation allowed by law. The representation provided by the Tsimpedes Law Firm is for compensation only.
[3] AGREEING WITH AND FULL UNDERSTANDING OF THIS AGREEMENT
If you agree with the above terms and conditions, please sign your name below. If you do not understand any part of this agreement, please request an explanation. Sign this agreement only after you fully understand and agree with all of its terms and conditions.
____________________________________________Date:________________
FIRM By: Athan T. Tsimpedes
____________________________________________Date:________________
Client:
INITIAL QUESTIONNAIRE
1. Please state the following information
A. Name:
B. Address
C. Age:
D. Occupation:
E. Contact numbers phone: mobile/cell: email:
2. Please state the circumstances or facts in which you provided money to the TRNC or its agents, directly or indirectly, include how you became aware of the property, the name of the real estate agents and attorneys involved, government documents:
PROPERTY INFORMATION (if more than one property, please duplicate this step for each property)
Description of the property and use (commercial or residential):
Location:
Address:
Witnesses:
Name:
Contact info:
Please attach any document from the TRNC Land Registry as proof of the property.
Please describe any prior owners who were listed in any of the transaction documents:
3. Copy of any and all documents establishing your payments for TRNC property.
4. Copy of all settlement papers, banking statements correspondents regarding your transaction with the TRNC, or its agents, regarding the property.
5. Please provide any additional information or documents that you feel will assist us in understanding your claims, including any judgments you may have obtained against anyone involved in taking your money:
By signing below, you swear under penalty of perjury that the information and contents provided herein are true and correct based on your personal knowledge.
__________________________ dated:
Client
Print Name:
If you have any questions please contact our office at 001-202-772-3159 or contact us by email
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