Petition Regarding Eviction of Tenant and Collection of Unpaid Rent

TO THE DUTY CIVIL COURT OF PEACE

[CITY NAME]

PLAINTIFF: [Name and Surname] – (Turkish Republic Identity Number: …) – [Address]

ATTORNEY: [Attorney's Name and Surname] – [Address] – [Tel]

DEFENDANT: [Name and Surname] – [Address]

SUBJECT: This is a claim for the eviction of the rented property due to default and the collection from the defendant of the outstanding rent amount of [Remaining Rent Amount] TL for the months specified.

EXPLANATIONS:

1. The defendant resides as a tenant in the property located at [Address], which is registered in my client's name. According to the lease agreement between the parties, rent payments must be made on the specified dates and to the specified account. However, the defendant has been experiencing delays in rent payments for a long time, causing my client financial losses.
2. A lease agreement was signed between the defendant and my client on [Date]. Despite the obligations clearly stated in the lease agreement, the defendant has not made regular payments and has been late with the rent. My client has repeatedly called the defendant, explaining that such behavior is not beneficial to either of them and inviting them to reach an agreement, but despite these written and verbal suggestions and conciliatory attitudes, the defendant has remained unresponsive.
3. While it was initially agreed that rent payments would be made to [Name of Receiver], my client requested, via a notice dated [Date] and numbered [Notice Number] from [Notary Name] Notary Public, that the rent payments be deposited into his/her account. Despite this notice being served directly to the defendant, it proved ineffective, and no regularity was established regarding rent payments.
4. Subsequently, [Person's Name], who signed the lease agreement, notified the defendant [Tenant's Name] via a notice from [Notary's Name] Notary Public dated [Date] and bearing [Daily Record Number] that rent payments should be made on behalf of my client. This notice was also served to the defendant. However, following this notification, the defendant's actions and attitude remained unchanged, as if no notification had been given; on the contrary, they began to insist on not making the payment.
5. The defendant tenant failed to pay the rent for the month of [October], and a notice was sent to him by [Notary Name] Notary Public on [Date] with [Notice Number]. This notice clearly stated that if the rent debt was not paid, an eviction lawsuit would be filed due to default. No payment was made by the defendant after the notice was served.
6. Furthermore, the defendant tenant has not paid the rent for month [X], and another notice has been sent to him informing him of this situation. Although this notice was also served on the defendant, no payment has been made. The defendant tenant has also failed to pay the rent for month [Y] of year [Year], thus violating his obligations as stated in the lease agreement.
7. My client has made several attempts to reach a settlement regarding the rent, even proposing payment plans to the defendant with the intention of facilitating payments. However, these efforts have been unsuccessful, and the defendant has persistently refused to pay the rent.

EVIDENCE:
We reserve the right to respond to the opposing party's evidence with our own;

1. Lease,
2. Photocopy of the title deed
3. The notices provided below are an additional notification
4. Bank statements and other legal evidence belonging to the plaintiff's client.

LEGAL GROUNDS: Turkish Code of Obligations, Turkish Code of Civil Procedure, and related legislation.

CONCLUSION AND REQUEST: For the reasons stated above, reserving our rights to claim further amounts, I respectfully request and demand, on behalf of my client, that the defendant be ordered to pay the outstanding accumulated rent of [Remaining Rent Amount] TL; that the property located at [Address] belonging to my client be evicted due to default; and that the defendant be ordered to pay the court costs and attorney's fees. …/…/…

Defendant's Attorney

Lawyer's Name and Surname

Signature