….. TO THE MAGISTRATE LAW COURT
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Eviction claim due to the default of the tenant (two justified warnings)
FACTS : 1- The defendant tenant … has been residing as a tenant in the flat owned by my client, the Lessor …. and located at the address ……….. in the province ……., Yenimahalle district ……….. in accordance with the lease agreement dated ……… and is still paying monthly ……….. TL monthly rent.
2- In the lease agreement between the defendant ……. and my client ………., the rental fees are paid between the 15th and 20th days of each month …….. Bank of ……….. ……….. branch between the 15th and 20th days of each month. However, upon the defendant’s failure to pay the rent for the month of …….. in the year ……., a notice was drawn by my client on ………… by the ………… Notary Public on ………… and despite this, the defendant did not pay the rent for the month of April.
3- Likewise, due to the defendant’s failure to deposit the rent for the month of …….. of the year ………. to the relevant account on the dates specified in the contract, my client has drawn a notice dated ……… by the ………… Notary Public on the payment of the rent for the month of …… of the year ………., but the rent in question has not been paid by the defendant. The defendant has defaulted by not paying the rent despite two justified notices within a lease period. In addition, the defendant has a total of …….., which is the rent for the months of ……… and …….. of the year ………. TL, which is the rent for the months of and .
4- In this respect, due to the fact that the tenant has caused two justified notices within a lease period and has defaulted by not paying the rent, it has become necessary to open this eviction and rent receivable case.
LEGAL GROUNDS :
EVIDENCE : Lease agreement dated ………., notices dated ……… and …………. drawn by ……… Notary, title deed records, witness statement 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 grounds that the tenant has caused two justified notices in a lease period and has defaulted with this notice be accepted and that the defendant be evicted from the apartment at the above-mentioned address where the defendant is residing as a tenant, the collection of the total unpaid rent of …………TL, and the judicial expenses and attorney’s fees be left on the defendant.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
Lawyer……………….
(SIGNATURE)
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