Request for Eviction Due to New Ownership
TO THE HONORABLE COURT
…….
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Eviction Due to New Ownership and Necessity
CASE VALUE: One Year’s Rent …….
EXPLANATIONS: 1-The defendant is a tenant of the former owner of the house recently purchased by our client.
2- The apartment located at ……. was purchased by my client pursuant to the Land Registry Office’s transaction dated ../../…. and numbered ……… (a copy of the title deed is attached).
3- My client purchased the property where the defendant currently resides with the intention of using it as a residence. Therefore, pursuant to Article 7/d of Law No. 6570, the defendant was notified via an eviction notice issued by the ……. Notary Office on ……. with serial number ……, stating that the lease agreement previously entered into between the former owner of the residence and the defendant would not be extended.
4- According to this notice, the property was required to be vacated at the end of the lease term; however, the defendant failed to vacate the property. Therefore, we request that a decision be rendered ordering the defendant’s eviction from the property.
LEGAL BASIS: Law No. 6570 and Relevant Legislation
EVIDENCE: Lease Agreement, Eviction Notice, Title Deed
REQUEST: For the reasons stated above, we request that the court order the defendant’s eviction from the leased property due to new acquisition and need, that the defendant be held liable for litigation costs, and that, pursuant to the final paragraph of Article 164 of the Lawyers’ Law No. 1136, as amended by Law No. 4667, the court order the payment of attorney’s fees to us as attorneys.
PLAINTIFF’S ATTORNEY