Petition For Eviction Due To New Ownership
TO THE HONORABLE COURT
…….
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Eviction Due to New Acquisition and Necessity
CASE VALUE: One Year’s Rent …….
EXPLANATIONS: 1-The defendant is a tenant of the former owner of the house recently purchased by our client.
2-The apartment located at ……. was purchased by my client pursuant to the Land Registry Office’s transaction dated ../../…. and numbered ……… (A copy of the title deed is attached).
3-My client purchased the property where the defendant currently resides with the intention of using it as a residence. For this reason, the defendant was notified via a notice of eviction issued by the ……. Notary Office on ……. with serial number ……, in accordance with Article 7/d of Law No. 6570, that the lease agreement previously entered into between the former owner of the residence and the defendant would not be extended.
4-Although the property was required to be vacated at the end of the lease term pursuant to this notice, the defendant has not vacated the property. For this reason, we request a decision ordering the eviction of the defendant from the property.
LEGAL GROUNDS: Law No. 6570 and Relevant Legislation
EVIDENCE: Lease Agreement, Notice of Eviction, Title Deed
REQUEST: For the reasons stated above, we request a decision ordering the defendant’s eviction from the leased property due to new acquisition and need, the imposition of litigation costs on the defendant, and the award of attorney’s fees to us as attorneys pursuant to the final paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY