….. TO THE MAGISTRATE LAW COURT
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Eviction claim due to new acquisition of the leased property.
FACTS :
1- The defendant Lessee …., the property of which was acquired by my client Lessor ….. on …… and located at the address of ………. province, ………… district, …………., has been living as a tenant in accordance with the lease agreement dated ……….. with the previous owner and still pays monthly rent of ………..TL.
2- My client, the Lessor ….., on the date ……….., the date he acquired the flat in question, ……… Notary Public ……….., notified that “he acquired the leased property and that the lease agreement will not be extended for the new term after the expiry date of the contract period, ………….., and therefore he must evacuate the leased property until ……….”. However, the defendant did not evacuate the leased property despite the notice and the expiry of the lease period. As a matter of fact, my client did not accept the rental fee brought by the defendant for the last month, saying that the contract was not renewed.
3- The leased property was acquired later by my client and my client needs a residence. Because my client himself was living in rented accommodation elsewhere and bought the apartment in question with the bonus he received due to his retirement from the civil service and his savings.
4- On the other hand, my client sent a notice to the defendant about 6 months in advance and asked him to evict the tenant. However, the tenant does not evacuate the leased property. In this respect, it has become necessary to file this eviction case based on the reason for the subsequent acquisition of the leased property.
LEGAL GROUNDS :
EVIDENCE : Lease agreement dated ………., …………. ……… dated warning notice drawn by the notary public, title deed records, witness statements and all kinds of legal evidence when necessary.
TIME FOR ANSWER :
CONCLUSION AND REQUEST :
For the above-mentioned reasons, I request that our lawsuit filed on the basis of the subsequent acquisition of the lease and the need for housing be accepted and that the defendant be evicted from the apartment at the above-mentioned address where the defendant is residing as a tenant and that the judicial expenses and attorney’s fee be left on the defendant.
I would like to submit this request. Sincerely yours,
Plaintiff’s Counsel
Atty…………………
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