….. TO THE MAGISTRATE LAW COURT
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : Eviction request based on the eviction undertaking.
FACTS : 1- The defendant tenant … is residing as a tenant in the apartment located at the address of ……. province, …….. district, ……………, owned by my client, the Lessor ……, in accordance with the lease agreement dated ………… and is still paying monthly ………. TL monthly rent.
2- After the defendant and my client concluded a 3-year lease agreement dated ………, they signed an eviction undertaking together at a notary public on ………… and in accordance with this undertaking, the defendant accepted and undertook to evacuate the flat fully and completely on ……….. and deliver it to my client.
3- However, the defendant did not evacuate the flat on ………., despite the eviction undertaking, and did not respond to the warning notice. For this reason, it has become necessary to file this lawsuit for the eviction of the defendant, for which enforcement proceedings have also been initiated.
LEGAL GROUNDS :
EVIDENCE : Lease agreement dated ……….., eviction undertaking dated ………, …… … Enforcement Directorate’s follow-up file …../…., title deed records, witness statements and all kinds of legal evidence when necessary.
RESPONSE TIME :
CONCLUSION AND REQUEST : For the above-mentioned reasons. I request that our lawsuit be accepted and the defendant be evicted. From the apartment at the above-mentioned address. Where the defendant is residing as a tenant, and that the judicial expenses and attorney. Fee be left on the defendant.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
Av………………
(SIGNATURE)
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