COURT OF PEACE
PLAINTIFF:
PLAINTIFF’S ATTORNEY:
DEFENDANT:
SUBJECT OF THE CASE: Request for eviction due to the tenant’s default. (Two justified notices)
FACTS: 1- The Defendant Tenant …, residing as a tenant in the apartment located at ……….. address in Yenimahalle district, ……. province, owned by my client the Lessor …, pursuant to the lease agreement dated ………, is currently paying a monthly rent of ……….. TL.
2- The lease agreement between the Defendant ……. and my client ………. stipulates that the rent shall be paid between the 15th and 20th days of each month to the account opened at the …….. Bank ……….. branch. However, when the defendant failed to pay the rent for the month of ……. in the year ……. , my client sent a warning letter through the ………… Notary Public on …………, but despite this, the defendant has not paid the rent for the month of April.
3- Similarly, since the defendant failed to deposit the rent for the month of ………. of the year …….. into the relevant account on the dates specified in the contract, my client sent a warning letter dated ……… through the ………… Notary Public regarding the payment of the rent for the month of ………. of the year ………. Despite this, the defendant failed to pay the rent in question. The defendant has defaulted by failing to pay the rent despite receiving two valid notices within one rental period. In addition, the defendant owes a total rent debt of ………. TL for the months of ……… and …….. of the year ………
4- Therefore, since the tenant caused two justified notices within one rental period and defaulted by failing to pay the rent, it has become necessary to file this eviction and rent claim lawsuit.
LEGAL GROUNDS:
EVIDENCE: The lease agreement dated ………, the notices of default dated ……… and …………. drawn up by the ……… Notary Public, land registry records, witness statements, and any other legal evidence as necessary.
RESPONSE PERIOD:
CONCLUSION AND REQUEST: For the reasons stated above, based on the tenant’s two justified notices during one rental period and his default due to these notices, we request that our lawsuit be accepted and that the defendant be evicted from the apartment located at the above address where he resides as a tenant, that the total unpaid rent of ………… TL, and that the defendant be ordered to pay the court costs and attorney’s fees.
Yours sincerely,
Plaintiff’s Attorney
Atty……………….
(SIGNATURE)
