COURT OF PEACE
PLAINTIFF:
PLAINTIFF’S ATTORNEY:
DEFENDANT:
SUBJECT OF THE CASE: Request for eviction due to the need for substantial repairs to the leased property.
FACTS: 1- The Defendant Tenant …, is residing as a tenant in the apartment located at ………… address, ……. district, ……. province, owned by my client the Lessor ….., pursuant to the lease agreement dated ………. and is currently paying a monthly rent of ………… TL.
2- Particularly in recent years, due to the earthquakes experienced in our country, the renewal of building permits has become an issue, and civil engineers have reported that additional iron supports must be installed to reinforce the columns supporting the apartment in order to renew the permit for the apartment belonging to my client.
3- Accordingly, my client sent a formal notice dated ……… through the notary public to the defendant Tenant ……… approximately 1.5 months before the end of the contract period. Notary Public, stating that “due to the mandatory repair of the leased property, the lease agreement will not be renewed for the new term and the tenant must vacate the leased property by the expiration date of the agreement on ……….” However, despite the notice and the expiration of the lease term, the defendant did not vacate the leased property. Indeed, my client has refused to accept the rent brought by the defendant for the last month, stating that the contract has not been renewed.
4- The property is in genuine need of substantial repairs, and it is clear that it is not possible to live in the apartment during the repairs. Indeed, we can prove this situation with reports prepared by construction engineers. However, the tenant has not vacated the leased property despite the fact that it is impossible to live in the leased property during its substantial repair. Therefore, it has become necessary to file this eviction lawsuit based on the need for substantial repair of the leased property.
LEGAL GROUNDS:
EVIDENCE: The lease agreement dated ………, the notice of default dated ………. drawn up by the ………. Notary Public, civil engineer reports, 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 substantial repair needs of the leased property, be accepted and that the defendant be ordered to vacate 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.
Yours sincerely,
Plaintiff’s Attorney
