Eviction Petition Based on Two Valid Reasons
TO THE HONORABLE COURT
…….
PLAINTIFF:…….
ATTORNEY:…….
DEFENDANT:…….
SUBJECT: Eviction due to two valid notices
VALUE OF CLAIM: ……. Annual rent.
EXPLANATIONS:
1-The defendant has been residing as a tenant in the apartment located at ……. address, which belongs to our client, under a lease agreement dated ……. The rent is ……. TL.
2-The defendant has not paid the rent for the months of ……. within the specified period. Our client has sent two valid notices to the defendant; one dated ……. and numbered ……. by the ……. Notary, and the other dated …/…/… and numbered …….. by the ………. Notary.
3-Despite this, the defendant has not made any payment. We request the eviction of the defendant from the rented property.
LEGAL BASIS: Article 7/e of Law No. 6570 and other relevant legislation.
EVIDENCE: Rental agreement, notices, and all other evidence.
RESPONSE PERIOD: 10 days
REQUESTED OUTCOME: For the reasons stated and since two valid notices have been served on the defendant, we request the eviction of the defendant from the rented premises, the imposition of litigation costs on the defendant, and the appointment of counsel for the opposing party in accordance with the last paragraph of Article 164 of the Lawyers’ Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY