Civil Court of First Instance
PLAINTIFF:
PLAINTIFF’S ATTORNEY:
DEFENDANT:
SUBJECT OF THE CASE:
Request for eviction due to the tenant’s default. (Two reasoned notices)
FACTS: 1- My client, the Lessor … owns the apartment located at……….. Address in Yenimahalle district, ……. province, where the Defendant Tenant.. Resides as a tenant under the lease agreement dated ……….. and pays a monthly rent of ……….. TL.
2- The lease agreement between the Defendant……. And my client ………. stipulates that the rent shall be paid between the 15th and 20th of each month to the account opened at the …….. Bank ……….. branch. However, when the Defendant failed to pay the rent for the month of……. In the year ……. , my client sent a formal notice through the ………… Notary on …………, but the Defendant still did not pay the rent for the month of April.
3- Similarly, when the defendant failed to deposit the rent for the month of………. Of the year…….. ınto the relevant account on the dates specified in the contract, my client sent a formal notice dated ………. through the ………. Notary regarding the payment of the rent for the month of ………. of the year ………. Nevertheless, the defendant did not pay the rent in question. The defendant defaulted by failing to pay the rent despite receiving two valid notices during the same rental period. Furthermore, the defendant owes a total of ………. TL in rent for the months of ……… and …….. of the year ………
4- Consequently, the tenant’s failure to pay rent and defaulting on the lease twice within one lease period has made it necessary to file this eviction and rent claim lawsuit.
LEGAL BASIS:
EVIDENCE: The lease agreement dated ………, notices of default dated ……… and ………… issued by the ……… Notary Public, land registry records, witness statements, and other necessary legal evidence.
RESPONSE PERIOD:
CONCLUSION AND REQUEST: For the reasons stated above, due to the tenant issuing two justified notices within one rental period and failing to comply with these notices, we request that our case be accepted, that the defendant be evicted from the apartment located at the above address where they reside as a tenant, and that the defendant be ordered to pay the total unpaid rent of ………… TL in unpaid rent, and the payment of court costs and attorney’s fees by the defendant.
Sincerely,
Attorney for the Plaintiff
Attorney……………….
(SIGNATURE)