-SAMPLE PETITION-
ANKARA SENTRY ENFORCEMENT OFFICE
Evacuation
REQUEST
SITUATED
PROSECUTOR :
ADDRESS :………
ATTORNEY :
ADDRESS :
PHONE:
DEFENDANT :
ADDRESS :…
SUBJECT OF REQUEST : Made by the defendant (the debtor of the Enforcement Directorate File) …/…./…. this is our request for eviction due to the cancellation of the dated appeal and default.
INSTRUCTIONS
Defendant C….. E…., at the place of work whose property belongs to the plaintiff client ../../…. he/she lives as a tenant in accordance with the lease agreement dated from the beginning (ANNEX-1). According to the contract concluded between the parties, the monthly rental price of the rented workplace is 000 dec00TL and will be paid on the first day of each month.
Despite the contract concluded between the parties, the defendant did not pay the last … monthly rent until the deci-sion date, Ankara ….Executive Directorate ‘s 2021/….. A payment order (ANNEX-2) has been sent to the tenant who owes the payment order over the total principal receivable of TL 000.00, which is equivalent to the unpaid rent with the numbered main file../../….it has been communicated in history.
Respondent debtor to the follow-up request …/…./…. although he has appealed in his history, this appeal is unfair and malicious. In this way, we reserve our rights and demands regarding the unjustified appeal of the defendant tenant who has not paid the rental fees and is in default, and the follow-up fee that he has not paid; The obligation to request that the real estate subject to the lease agreement be decided to be evicted due to default has arisen.
LEGAL REASONS : IIK (156 and all other articles), HMK, Av. Law and other relevant legislation
EVIDENCE : Ankara ….Executive Directorate ‘s 2021/….. E. Subpoenaed file No., ../../…. The Lease Agreement with the Initial Date, the Expert report (If Deemed Necessary), Etc. any kind of delail
CONCLUSION AND CLAIM: For all the reasons described above and which will be considered by your court you’re,
1-ACCEPTANCE OF our Case, CANCELLATION OF the Appeal and CONTINUATION OF THE PROCEEDINGS,
2-Evacuation of the Rented Place Due to Default and Its Delivery as Empty,
3-We offer and request that it be decided that the costs of the trial and the power of attorney be left on the counterparty. 16/09/2021
Who Requested Eviction