……. TO THE HONOURABLE JUDGE
…….
CLAIMANT :…….
DEFENDANT :…….
DEFENDANT :…….
SUBJECT : Eviction Due to Reconstruction
CASE VALUE : Annual Rent …….
EXPLANATIONS :1- The defendant is the tenant of our client. He lives in the two-storey wooden house at the address ……., which belongs to our client, with a written lease agreement dated ……. and paying a monthly rent of ……..
2-Our client will demolish the building in question and build a new construction instead. The project works regarding the building to be constructed have been completed. The necessary applications have been made and the construction licence has been obtained.
3-This situation has been notified to the tenant in accordance with Article 7/ç of the Law No. 6570 ……. ……. date and ……. journal numbered notice of the ……. Notary Public. Despite this, the defendant tenant did not evacuate the immovable.
Therefore, we demand the eviction of the immovable.
LEGAL GROUNDS : Law No. 6570 and Related Legislation
EVIDENCE : Lease Agreement, Notice, Project, Construction Licence.
RESULT OF THE REQUEST : For the reasons explained. We request that the defendant be evicted from the leased property due to reconstruction, 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 Law No. 1136 on Attorneys amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
…….
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