Petition for Collection of Rent and Electricity Usage Fees

TO THE DUTY CIVIL COURT OF PEACE
, ISTANBUL

PLAINTIFF: Name and Surname (Turkish Republic Identity Number: …) – Address
REPRESENTATIVE: Lawyer's Name and Surname – Address
DEFENDANT: Name and Surname – Address

SUBJECT: Claim for collection of outstanding rent and electricity usage fees paid by the client, along with legal interest from the payment dates.
VALUE OF CLAIM: … TL

EXPLANATIONS:

1. My client rented the premises at … address to the defendant … on … date. However, the defendant tenant has not paid any of the rent from … date to X … date. He defaulted on payments including the month of Y … and, despite repeated requests for rent, , without paying any rent .
2. An enforcement proceeding without a court order was initiated against the defendant tenant on …/…/… by the … Enforcement Directorate under file number …/…. However, this proceeding was halted by the defendant tenant's objection on …/…/…. The proceeding was dismissed due to the defendant tenant's failure to take any action regarding the file.
3.  As it was later discovered, the defendant tenant also failed to pay the electricity bills for the property, and the client was forced to make a payment of …/…/… TL to the defendant on …/…/… for electricity usage. (Appendix - Sample receipt dated …/…/…). This lawsuit was filed because the defendant tenant used the property from month X to month Y without making any payment, and the enforcement proceedings initiated against the defendant proved unsuccessful.
4. Furthermore, the defendant tenant damaged my client's belongings after vacating the rented property, causing some items to go missing. An expert examination has been requested to determine and compensate for these damages.

EVIDENCE:

1. File number 2009/14383 E. of Bakırköy 2nd Enforcement Office
2. Sample payment receipt
3. Witness statements
4. Expert report
5. Photographs showing damage to the client's belongings during the eviction process
6. Other legal evidence

LEGAL GROUNDS: Turkish Civil Code and related legislation.

CONCLUSION AND REQUEST: In light of the reasons briefly presented and explained above, I respectfully request and demand that the court accept the case and, reserving our rights regarding any further claims, order the defendant tenant … to pay the rent of … TL from …/…/… to …/…/… with applicable legal interest as of the payment dates, and the electricity bill of … TL with legal interest starting from …/…/…; that a separate investigation be conducted regarding the compensation for damaged items; and that the court costs and attorney's fees be collected from the defendant. …/…/…

Plaintiff's
Attorney's Name and
Surname