…… MAGISTRATE LAW COURT
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Eviction request due to the need for substantial repair of the leased property.
FACTS :
1- The defendant tenant …., the property of which belongs to my client Lessor ….. and located in ……. province, …….. district, ………… address, has been living as a tenant in accordance with the lease agreement dated ………. and still pays monthly rent of ………… TL.
2- Especially in recent years, due to the earthquake events in our country, the renewal of building licences has come to the agenda and in order to renew the licence of the apartment belonging to my client, it has been reported by civil engineers that additional iron supports should be placed to strengthen the columns that support the apartment.
3- In this respect, my client sent a letter to the defendant tenant ……. approximately 1.5 months before the expiry of the contract period ………. ……… through the ……… Notary Public and warned that “the lease agreement will not be renewed for the new term due to the compulsory repair of the lease in question and that he must evacuate the lease until the expiry date of the contract period, ………”. 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.
4- The need for substantial repair of the leased property is real and it is obvious that it is not possible to live in the apartment during the said repair. As a matter of fact, it is possible to prove this situation with reports prepared by civil engineers. However, the tenant does not evacuate the leased property despite the fact that it is not possible to live in the leased property during the essential repair of the leased property. In this respect, it has become necessary to open this eviction case based on the need for substantial repair of the leased property.
LEGAL GROUNDS :
EVIDENCE : Lease agreement dated ………, ………. ………. dated warning notice drawn by the notary public, civil engineer reports, 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 need for substantial repair of the leased property 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.
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