Petition For Eviction Due To New Acquisition Of The Leased Property
COURT OF PEACE
PLAINTIFF:
PLAINTIFF’S ATTORNEY:
DEFENDANT:
SUBJECT OF THE CASE: Request for eviction due to new acquisition of the leased property.
FACTS: 1- Defendant Tenant …, acquired ownership of the apartment located at …………. address in ………… district, ………… province, on …… date, and is currently residing as a tenant pursuant to the lease agreement dated ……….. with the previous owner, and is still paying a monthly rent of ………..TL.
2- My client, the Lessor ….., acquired the apartment in question on ……….. However, despite the notice and the expiration of the lease term, the defendant has not vacated the leased property. Indeed, my client did not accept the rent brought by the defendant for the last month, stating that the contract had not been renewed.
3- The leased property was subsequently acquired by my client, who has a need for housing. This is because my client himself lives in rented accommodation elsewhere and purchased the apartment in question with the severance pay he received upon retirement from civil service and his savings.
4- Furthermore, my client sent a warning letter to the defendant approximately 6 months ago requesting the eviction of the tenant. However, the tenant has not vacated the premises. Therefore, it has become necessary to file this eviction lawsuit based on the subsequent acquisition of the leased property.
LEGAL GROUNDS:
EVIDENCE: The lease agreement dated ………. the notice of eviction dated ……… drawn up by the …………. Notary Public, title deeds, witness statements, and any other legal evidence as necessary.
RESPONSE PERIOD:
CONCLUSION AND REQUEST: For the reasons stated above, I request that our lawsuit, filed based on the subsequent acquisition of the leased property and housing needs, be accepted, that the defendant be evicted from the apartment located at the above address where he resides as a tenant, and that the defendant be ordered to pay the court costs and attorney’s fees.
I respectfully submit this request.
Plaintiff’s Attorney
Attorney………………