….. TO THE MAGISTRATE LAW COURT
THE PLAINTIFF :
PLAINTIFF’S ATTORNEY :
DEFENDANT :
SUBJECT OF LAWSUIT : Eviction request based on the eviction undertaking.
FACTS : 1- The defendant Tenant … is residing as a tenant in the apartment owned by my client Lessor …… and located at the address of ……. province, …….. district …………… 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 premises fully and completely on ……….. and to deliver it to my client.
3- However, the defendant did not evacuate on ………., despite the eviction undertaking, and did not respond to the notice of warning. 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 with …../…. principal number, title deed records. Witness statements and all kinds of legal evidence when necessary.
ANSWER 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 this request. Sincerely yours,
Counsel for the Plaintiff
Hunting………………
(SIGNATURE)
ANNEX:
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