COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT OF THE CASE : It consists of the request for the termination of the lease agreement and the eviction of the defendant due to the expiration of the fixed-term lease agreement.
FACTS : 1- The defendant ……………. is residing as a tenant in the apartment owned by my client ………….. and located in ………… province, …………. district ……………. in accordance with the lease agreement dated ………….. and is still paying monthly ………. TL monthly rent.
2- In the article ….. of the part of the lease agreement made between the defendant and my client under the title of special provisions; ‘the lease agreement is made for one year, at the end of each lease period, if the parties agree, the lease agreement will be deemed to be extended for one year, when one of the parties wants to terminate the contract, it can terminate the lease agreement by notifying the other party at least one month in advance of 1 July, the end of the lease period’.
3- Since my client does not want the lease agreement to be renewed for the new lease period after the date of ………., he notified the defendant with the notice of …………. date and (……….) dated …………. and numbered (……) of …………. (……) Notary Public and notified that ‘the lease agreement will not be renewed for the new term and the lease agreement will expire on ………., therefore the defendant must evacuate the leased property within …. days from ……..’.
4- Although the defendant has personally notified the aforementioned notice on ………., he has not evicted the leased premises until today and has not paid the rent. In this respect, it has become necessary to file this lawsuit in order to decide on the eviction of the defendant and the termination of the lease agreement.
LEGAL GROUNDS :
EVIDENCE : Lease agreement dated ……….., ………. (….) Notary’s notice dated ……… and numbered (………..), Land Registry Records, witness statements and all kinds of legal evidence when necessary.
CONCLUSION AND REQUEST : For the above-mentioned reasons, with the acceptance of our lawsuit, we respectfully request and demand the eviction of the tenant who is found as a tenant in accordance with the lease agreement dated ……… in the lease belonging to my client, who has not evicted the lessor despite the expiration of the lease agreement and the renewal of the lease agreement, the termination of the lease agreement and the decision to leave the costs of the proceedings and the attorney fee on the defendant. ../../..
Plaintiff Attorney
Hunting………………….
(SIGNATURE)
ANNEX: