……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
DEFENDANTS :…….
DEFENDANT :…….
SUBJECT : EVICTION DUE TO NECESSITY
(Monthly Rental Fee …….)
EXPLANATIONS :1-While the defendants were sitting as the tenant of ………. ………….. with an oral lease agreement on the immovable. Property whose open address is written under their names. Our client transferred and purchased the said immovable property on 01.02.1999 from ……….. ………… on 01.02.1999 and this transfer. Was recorded in the co-operative decision book.
2- Based on the verbal agreement previously concluded. By the defendants with the former owner and based on the right of ownership of our client as the successor. Of the former owner, the defendant ……. 1st Notary of dated 17.02.1999 with the date of 17.02.1999 and journal number 4389, and with this notice. Our client was notified that the contract. Would not be renewed due to his own need and that he wanted to evacuate. This notice was served to the signature of the resident ……….. together with the defendants on 06.03.1999.
3-Defendants did not evacuate the property despite this notice. Our client’s need is real and sincere. Our client is currently living as a tenant in the immovable property. Whose address is written under his name. With a written lease agreement dated 06.07.1998 and dated one year. Our client does not have a house other than the house where the defendant lives. He will live in this house himself.
4-In order to ensure the eviction of the defendant. Who did not evacuate the immovable property despite the warning, …… 2 Civil Court of Peace on ../../…. on ../../…. E. Although an evacuation lawsuit. Was filed due to need with the number. This lawsuit was rejected due to time.
5- The lawsuit filed before …… 2 Civil Court of Peace on ../../…. on ../../…. Although the lawsuit filed with the number E. was filed based on the date of 25.03.1996, the defendant claimed in the reply petition dated. 13.05.1999 that the lease commencement. Date was 15.04.1995, not 25.03.1996, and therefore the lawsuit filed for this reason was rejected in terms of duration.
6-Since the first lawsuit filed. Will be considered as a warning and in order to ensure the eviction of the defendants. Who did not evacuate the immovable property despite this warning. It has become necessary to file this lawsuit.
LEGAL GROUNDS Law No. 6570 and Related Legislation
EVIDENCE :…. 2 Civil Court of Peace ../…. File No. E. and File Contents, Cooperative Decision Book, Notice, Lease Contract. That our client lives in rent, Bank Receipts, Witnesses, Expert Examination, Other Legal and Discretionary Evidence etc.
CONCLUSION OF THE REQUEST : For the reasons stated above. We request that the defendant be evicted from the immovable property. That the defendant be charged with the costs of the proceedings, and that the counterparty attorney. Fee be awarded on our behalf as a lawyer in accordance. With the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
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