TO THE CIVIL COURT OF MAGIC
Plaintiff:
ATTORNEY’S ATTORNEY:
DEFENDANT:
SUBJECT OF CASE: It is a request for evacuation due to the basic repair need of the leased person.
EVENTS: 1- Defendant Tenant …., property belongs to my client Lessor ….. and, ……. city, …….. district ………… in the flat at …………. He also resides as a tenant in accordance with the initial lease agreement and still pays ………… TL monthly rent.
2- Especially due to the earthquake events in our country in recent years, the renewal of the building licenses has come to the fore, and it has been reported by the civil engineers that additional iron supports should be put in order to strengthen the columns that sustain the flat in order to renew the license of my client’s flat.
3- In this respect, my client, the defendant Tenant ……., with approximately 1.5 months remaining before the expiry of the contract period, ………. He issued a warning dated ……… through his notary public and warned that «the lease contract will not be renewed for the new term due to the compulsory repair of the leased property and he must evacuate the leased property until the expiry date of the contract, ………». However, the defendant did not evacuate the leased property despite the notice and the expiry of the lease term. As a matter of fact, my client did not accept the rental fee brought by the defendant for the last month, saying that the contract was not renewed.
4- It is obvious that the rented property needs major repairs and it is not possible to live in the flat during the said repair. As a matter of fact, it is possible to prove this situation with the reports prepared by civil engineers. However, the lessee does not evacuate the leased property even though it is not possible to live in the leased property during the major repair. In this respect, it has become necessary to open this eviction lawsuit based on the need for substantial repair of the leased person.
LEGAL REASONS :
EVIDENCE: Rental agreement dated ………, ………. Taken by the notary public ………. dated warning, civil engineer reports, land registry records, witness statement and all kinds of legal evidence when necessary.
ANSWER TIME:
CONCLUSION AND REQUEST: With the acceptance of our lawsuit, which was filed based on the above-mentioned reasons, based on the need for substantial repair of the leased property, I request that the defendant evacuate the flat at the above-mentioned address where he resides as a tenant, and that the trial expenses and attorney’s fee be left on the defendant.
I offer. Kind regards,
Plaintiff’s Attorney
Lawyer
