Petition For Eviction And Claim For Compensation Due To Breach Of Contract Provisions
TO THE MAGISTRATE LAW COURT
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF LAWSUIT : Eviction due to breach of the terms of the contract and ………. TL compensation claim.
FACTS : 1- The defendant Tenant …… has been living as a tenant in the apartment owned by my client Lessor ……….. and located at the address ……, ……… district …… Street No: …… in …… province, ……… district, ………. in accordance with the three-year lease agreement with the starting date ………. and still pays monthly rent of ……… (…………..) TL.
2- As stated in the lease agreement between the defendant Lessee …… and my client Lessor ……., the lessee will protect and take care of the leased property with the degree of care required and will not damage the fixtures in the leased property. However, the tenant ….. acted contrary to the provisions of the contract and water overflowed onto the parquet flooring on the floor of all rooms of the apartment due to the bathroom faucets remaining open and the flooring of the entire apartment became unusable.
3- Upon this situation, my client sent a notice to the defendant to eliminate the breach of contract and repair the parquets of the apartment ……….. on …………. and despite this, the defendant did not remove the breach of contract and repair the parquet floors. The damage caused by the defendant to the apartment is estimated to be around ………… TL, as will be determined by discovery and expert reports.
4- In this respect, since the tenant has acted contrary to the provisions of the contract and caused damage due to the tenant’s failure to show the necessary care and attention in the leased property, it has become necessary to open this eviction and compensation lawsuit in an amount to cover the damage due to breach of contract.
LEGAL GROUNDS :
EVIDENCE : Lease agreement dated ………., …… …….. …………. dated warning notice drawn by the Notary Public, discovery and expert report, land registry records, witness statements and all kinds of legal evidence when necessary.
RESPONSE PERIOD :
CONCLUSION AND REQUEST : For the above-mentioned reasons, with the acceptance of our lawsuit filed due to the tenant’s violation of the provisions of the contract, the defendant’s eviction of the apartment at the above-mentioned address where the defendant is residing as a tenant, the total amount of damage caused by the tenant to the apartment ……….. TL, the amount of damage caused by the tenant to the apartment, and that the judicial expenses and attorney’s fee be left on the defendant.
I would like to submit. Sincerely yours,
Counsel for the Plaintiff
Atty………………..
(SIGNATURE)
