Petition For Eviction Due To Tenant’s Default Following Two Valid Notices
COURT OF PEACE
PLAINTIFF (TC) :
ATTORNEYS :
ADDRESS :
DEFENDANT (TC) :
ADDRESS :
SUBJECT : Our request for eviction due to the tenant’s default after two valid notices.
EXPLANATIONS: 1- The defendant tenant resides as a tenant in the apartment belonging to the client and located at the address of …, pursuant to the lease agreement dated …/…/…, and currently pays a monthly rent of … TL.
2- Initially paying rent regularly, the defendant later began to fail to pay rent on time. Upon the defendant’s failure to pay the rent for the month of … in the year …, as specified in the agreement, the client notified the defendant to pay the rent by means of a warning letter dated …/…/… and numbered … by the … Notary Public.
3- The defendant, who did not pay the rent for the month in question despite the warning letter, also failed to pay the rent for the following month. Upon this, secondly, our client notified the defendant by means of a second warning letter dated …/…/… and numbered …… by the … Notary Public, demanding payment of the rent for both months and warning that otherwise, an eviction lawsuit would be filed. Despite this, the tenant has not paid the overdue rent and has not vacated the property.
LEGAL GROUNDS: The Law of Obligations and other relevant legislation.
LEGAL EVIDENCE: The lease agreement dated …/…/…, … The notary’s warning letter dated …/…/… and numbered … (first warning letter), the notary’s warning letter dated …/…/… and numbered … (second warning letter), land registry records, witness statements, and any other legal evidence as necessary.
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully request and demand that the defendant tenant, who has been sent two justified notices for failing to pay rent within a rental period, be evicted from the rented property, that the unpaid rent of … TL be collected on behalf of our client, and that the defendant be charged with the costs of the proceedings.
Plaintiff’s Attorney
Attorney