TO THE CIVIL COURT OF PEACE
PLAINTIFF (TC):
ATTORNEYS:
ADDRESS:
DEFENDANT (TC):
ADDRESS:
SUBJECT: This consists of our request for eviction due to the tenant’s default with two justified warnings.
EXPLANATIONS: 1- The defendant tenant belongs to the client and …. He lives as a tenant in the flat located at …/…/… in accordance with the lease agreement with the starting date and currently pays a monthly rent of … TL.
2- The defendant, who initially paid his rent regularly, started not paying the rent on time after a while. Defendant’s … year …. Upon failure to pay the rent for the month on the dates specified in the contract, …. With the notary public’s notice dated …/…/… and journal number ……, our client notified the defendant to pay the rent.
3- The defendant, who did not pay the rent of the month in question despite the warning, did not pay the rent of the next month either. On top of that, secondly, …. With the notary public’s notice dated …/…/… and journal number ……, our client notified the defendant that he must pay the rent for every two months, otherwise he would file a lawsuit for eviction. Despite this, the tenant did not pay the overdue rents and did not evacuate the property.
LEGAL REASONS: Law of Obligations and other relevant legislation.
LEGAL EVIDENCE: Lease agreement dated …/…/…, …. Notary Public’s notice dated …/…/… and journal number…… (first notice), …. Notary public’s notice (second notice) dated …/…/… and journal number……), title deed records, witness statement and all kinds of legal evidence when necessary.
CONCLUSION AND REQUEST: For the reasons explained above, we respectfully and hereby submit and request that the defendant tenant, to whom two justified warnings were sent for not paying the rental fees within a rental period, be evacuated from the leased property, the unpaid rental fee of … TL be collected on behalf of our client, and the litigation expenses be charged to the defendant.
Plaintiff’s Attorney
Av.