MAGISTRATES ‘ COURT
PLAINTIFF (TC) :
PROXIES :
address :
DEFENDANT(TC) :
address :
SUBJECT : It consists of our eviction request due to the tenant’s default with two justified warnings.
EXPLANATIONS : 1- The defendant tenant belongs to the client and …. in the apartment located at the address … /… /… he lives as a tenant in accordance with the lease agreement dated the beginning and still pays a monthly rent of … TL.
2- The defendant, who initially paid his rents regularly, started not paying the rents on time after a while. The defendant’s … year …. upon failure to pay the rental price of the month on the dates specified in the contract, …. With the notary’s … /…/… date and …… journal numbered notice, our client has informed the defendant to pay the rent price.
3- The defendant who did not pay the rent of the month in question despite the warning, did not pay the rent of the following month. On top of that , secondly, …. With the notary’s … /…/… date and …… journal numbered notice, our client informed the defendant that he must pay the rent for both months, otherwise he will file a lawsuit for eviction. Despite this, the tenant did not pay the overdue rents and did not evict the immovable.
LEGAL REASONS: The Code of Obligations and other relevant legislation.
LEGAL EVIDENCE : …/…/… dated lease agreement, …. Notary’s … /… /… date and …… journal numbered warning (first warning), …. Notary’s … /… /… date and …… journal numbered warning (second warning), land registry records, witness statement and all kinds of legal evidence when necessary.
CONCLUSION AND CLAIM: For the reasons described above, we respectfully and kindly offer and request bilvekale to decide on the eviction of the defendant tenant, who has been sent two justified warnings for not paying the rental fees during the rental period, the collection of the unpaid rent paid … TL on behalf of our client, the burden of the trial costs on the defendant.
Plaintiff Attorney
Lawyer.
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