Petition For Cancellation Of Objection And Eviction Case
-SAMPLE PETITION-
ANKARA DUTY ENFORCEMENT JUDGE
RELEASE
IN REQUEST
FOUND
THE PLAINTIFF :
ADDRESS :………
REPRESENTATIVE :
ADDRESS :
TELEPHONE :
DEFENDANT :
ADDRESS :…
SUBJECT OF THE DEMAND :
It is our request for cancellation of the objection dated …/…./…. made by the defendant (debtor of the Enforcement Directorate File) and evacuation due to default.
EXPLANATIONS
Defendant C….. D…. lives as a tenant in the workplace owned by the plaintiff client in accordance with the lease contract (Annex-1) dated ../../….. According to the contract between the parties, the monthly rent of the rented workplace is 000,00TL and will be paid on the … day of each month.
Despite the aforementioned contract concluded between the parties, since the defendant has not paid the last … monthly rent until the date of follow-up, Ankara …. Enforcement Directorate’s 2021/….. With the file numbered 2021/…., a payment order (Annex-2) was sent over the original receivable of TL 000.00, which is the unpaid rent; the payment order was notified to the debtor tenant on ../../…..
Although the defendant debtor objected to the follow-up request on …/…./…., this objection is unfair and malicious. In this way, it has become necessary to request the removal of the unjustified objection of the defendant tenant, who has not paid the rent and defaulted, and the eviction of the immovable subject to the lease agreement due to default, without prejudice to our rights and claims regarding the follow-up fee that he has not paid.
LEGAL GROUNDS :
İİK (156 and all other articles), HMK, Law on Attorneys and other relevant legislation
EVIDENCE :
Ankara …. Enforcement Directorate’s file numbered 2021/….. E. numbered file subpoena, ../../…. Start Date Lease Contract, Expert report (If deemed necessary), Any other evidence
CONCLUSION AND REQUEST:
For all the reasons explained above and to be taken into consideration by your Court ex officio,
1-Acceptance of our lawsuit, cancellation of the objection and continuation of the proceedings,
2-Evacuation of the Leased Place due to Default and Delivery as Empty,
3- We request and demand that it be decided to leave the trial expenses and attorney’s fee on the other party. 16/09/2021
Requesting Eviction
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