…… CIVIL COURT
Plaintiff:
ATTORNEY FOR THE PLAINTIFF:
DEFENDANT:
SUBJECT OF THE CASE: Request for eviction due to the tenant’s need for essential repairs.
FACTS: 1- The Defendant Tenant …, resides in the apartment located at ………… address, …….. district, ……. city, which belongs to my client, the Lessor …… Furthermore, he continues to reside as a tenant in accordance with the initial lease agreement and continues to pay a monthly rent of ………… TL.
2-
Particularly due to the earthquakes that have occurred in our country in recent years, the renewal of building permits has become an issue, and civil engineers have reported that additional iron supports need to be installed to reinforce the columns supporting the apartment in order to renew the permit for my client’s apartment.
3- In this context, approximately 1.5 months before the end of the contract period, my client sent a warning to the defendant Tenant ………. notary public, stating, “Due to the mandatory repair of the leased property, the lease agreement will not be renewed for the new term, and the leased property must be vacated by the end of the contract date, ……….”. However, despite the warning and the end of the lease term, the defendant did not vacate the leased property. Indeed, my client refused to accept the rent for the last month brought by the defendant, stating that the contract had not been renewed.
4- It is clear that the leased property requires major repairs and that it is impossible to live in the apartment during the repair period. This can be proven by reports prepared by construction engineers. However, despite the fact that it is impossible to live in the leased property during the major repairs, the tenant has not vacated the leased property. In this context, it has become necessary to file this eviction lawsuit based on the tenant’s significant repair needs.
LEGAL GROUNDS:
EVIDENCE: Rental agreement dated ………. warning issued by a notary public dated ………. civil engineer reports, title deeds, witness statements, and any other legal evidence as necessary.
RESPONSE TIME:
CONCLUSION AND REQUEST: Based on the reasons stated above and the need for significant repairs to the leased property, I request that the lawsuit we have filed be accepted, that the defendant vacate the apartment at the above address where he resides as a tenant, and that the defendant bear the costs of the lawsuit and attorney’s fees.
I hereby submit this request. Sincerely,