Eviction Of Workplace Due To Non-Payment Of Rent – Petition For Cancellation Of Objection
ANTALYA COURT OF PEACE ON DUTY
EXECUTION FILE NO:
THE PLAINTIFF : (Name, Surname, T.R. ID No., Address)
AGENT : Atty.(Name, Surname, Address)
DEFENDANT : …..
SUBJECT : Due to unpaid rent debts ….. It is related to the request for eviction with the cancellation of the debtor’s objections due to the debtor’s objection to the proceedings registered in the file numbered … of the Enforcement Office.
EXPLANATIONS :
1 – The defendant … uses the real estate located at ………., which belongs to the client, as a workplace. Although it has been agreed between the client and the defendant regarding the rental price of the immovable by the defendant …..-TL rental fee to be paid on the 20th day of each month, …. The rent has not been paid by the defendant since …..
2 – Although the defendant has been repeatedly contacted regarding the payment, the defendant has delayed the client for months by stating that he will pay today and tomorrow, and has not made any payment in this process.
3 -… … Although enforcement proceedings were initiated against the defendant in the file numbered … of the Enforcement Directorate … regarding the debts and eviction related to the months of ….., the defendant objected to the proceedings unfairly and the proceedings were stopped.
For the reasons stated, we have had the necessity to request eviction due to non-payment of rents before the honorable court, cancellation of the unfair objection to the proceedings, collection of rent receivables and awarding execution denial compensation.
LEGAL REASONS : Turkish Code of Obligations, Execution and Bankruptcy Law and other relevant legislation.
LEGAL EVIDENCE : Enforcement File No. … etc. evidence
CONCLUSION AND REQUEST : For the reasons explained above, we respectfully request and demand the cancellation of the defendant’s unfair objection, the payment of the rental fees, the eviction of the defendant from the residence, and the decision to impose 20% execution denial compensation, attorney’s fee and litigation costs on the other party due to the unfair objection.
(Date)
DEFENDANT’S ATTORNEY
(Name, Surname, Signature)
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