……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : Eviction due to New Acquisition and Need
CASE VALUE : One year rent …….
EXPLANATIONS :
1- The defendant is the tenant of the former owner of the house that our client has just purchased.
2-The apartment, which is still located at ……., has been purchased by my client with the transaction of ……… Land Registry Office, dated …/../…. and numbered ………. (The copy of the title deed is attached)
3-Our client has purchased the property where the defendant is currently residing in order to use it as a residence. For this reason, the defendant was notified that the lease agreement made between the former owner of the house and the defendant will not be extended in accordance with Article 7/d of the Law No. 6570 ……. The defendant has been notified with the notice of the Notary Public dated ……. and numbered ……..
4- While the immovable must be evicted at the end of the lease period in accordance with this notice, the defendant has not left the immovable. For this reason, we request a decision to evict the immovable.
LEGAL GROUNDS : Law No. 6570 and Related Legislation
EVIDENCE : Lease Agreement, Notice, Land Registry
CONCLUSION OF THE REQUEST : For the reasons explained, we request that the defendant be evicted from the leased property due to new acquisition and need, that the defendant be charged with the costs of the proceedings, and that the counterparty attorney’s fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Law No. 1136 on Attorneyship Law amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
…….
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