Item 19 - Applicant's response to the Turkish Government's observations concerning just satisfaction

c. 30pp

Applicant's response to the Turkish Government's observations concerning just satisfaction in the Buldan case, noting that nothing in the Government's newly-submitted evidence (A44/43/1/19/2/12) undermines the existing claim as nothing in the documents pertains to any events which took place before the applicant fled to Germany in 1994, and that the submissions of the evidence only serves to delay the case proceedings further. The response also notes that even if the PKK did threaten Buldan to the point where Buldan had to flee the country, the Government should have provided protection to the necessary degree to protect his life. Attached to the response are copies of previously submitted documents, annexes, and appendices which substantiate Buldan's claims for just satisfaction, including land title deeds, Buldan family business records, and Buldan's letter to Sheldon Leader of 18 September 2003.

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