….. TO THE MAGISTRATE LAW COURT
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF LAWSUIT : Eviction due to breach of the terms of the contract and ………. TL compensation claim.
FACTS : 1- The defendant tenant …… is residing as a tenant in the apartment owned by my client, the Lessor ……….., located at …… Street No: …… in …… province, ……… district, ……, in accordance with the three-year lease agreement dated ………. and still pays monthly rent of ……… (…………..) TL.
2- As stated in the lease agreement between the defendant Lessee …… and my client Lessor ……., the lessee shall protect and take care of the leased property with the degree of care required and shall not damage the fixtures in the leased property. However, the tenant ….. acted contrary to the provisions of the contract and the parquet on the floor of all rooms of the apartment was flooded with water due to the bathroom taps remaining open and the floor of the entire apartment became unusable.
3- Upon this situation, my client sent a notice to the defendant to eliminate the breach of contract and to repair the parquet of the apartment ……….. on …………. and despite this, the defendant did not remove the breach of contract and repair the parquet floors. The damage caused by the defendant to the flat is estimated to be around ………… TL as it will be determined by discovery and expert reports.
4- In this respect, since the tenant has acted contrary to the provisions of the contract and caused damage due to not showing the necessary care and attention in the leased property, it has become necessary to open this eviction and compensation lawsuit in an amount to cover the damage due to breach of contract.
LEGAL GROUNDS :
EVIDENCE : Lease agreement dated ………., …… …….. …………. dated notice drawn by the notary public, discovery and expert report, land registry records, witness statements and all kinds of legal evidence when necessary.
RESPONSE PERIOD :
CONCLUSION AND REQUEST : For the above-mentioned reasons, with the acceptance of our lawsuit filed due to the tenant’s breach of the provisions of the contract, the defendant’s eviction of the apartment at the above-mentioned address where the defendant is residing as a tenant, the total amount of damage caused by the tenant to the apartment ……….. TL, which is the amount of damage caused by the tenant to the apartment, and that the judgement expenses and attorney’s fee be left on the defendant.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
Av………………..
(SIGNATURE)
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