Petition for Debt Collection Due to Default
TO THE HONORABLE COURT
…….
PLAINTIFF:…….
ATTORNEYS:…….
DEFENDANT:…….
SUBJECT: Eviction and rent claim due to default
AMOUNT CLAIMED: …….-TL.
EXPLANATIONS: 1-Our client ……., rented the residence located at……. Address to the defendant under a contract dated ……. and valid for ……. months.
2-Upon the defendant’s failure to pay the rent amount of……. For the months of ……. , a notification was served by the Notary on ……. , numbered……. Demanding payment of the rent debt within ……. payment period. However, despite being served on ……. date, the notice was unsuccessful, and the defendant defaulted by failing to pay the rent.
3-Furthermore, the defendant has not paid the rent for the month of ……. to date.
LEGAL BASIS: Turkish Civil Code, Code of Civil Procedure, other relevant legislation.
EVIDENCE: Rental agreement, notice,
RESPONSE PERIOD: 10 days
CONCLUSION: For these reasons, despite the notice sent, the defendant has defaulted by failing to pay the rent. Therefore, the defendant must be EVICTED from the property located at …… address. The total accumulated rent debt of …… and the costs of the default notice shall be COLLECTED from the defendant with legal interest from the date of the lawsuit. It has been decided that the litigation costs shall be borne by the defendant and that the opposing party’s attorney’s fees shall be paid to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney’s Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEYS