…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT: Eviction Due to Breach of Contract
VALUE OF CLAIM: Annual Rent Amount …….
EXPLANATIONS: 1-The Defendant has been residing as a tenant in the office located at ……. belonging to our Client, under a written lease agreement dated ……. and paying rent of …….
2-After occupying the office for approximately 4 years, the Defendant unconditionally and unreservedly agreed to vacate it on ……. by a letter of commitment given to our client of his own free will and at his own request after the beginning of the last term.
3-The defendant tenant, who failed to comply with his written commitment, was reminded of this commitment in accordance with Article 7/a of Law No. 6570 by a reminder dated ……. and numbered ……. and that, otherwise, he would be liable for all expenses and attorney’s fees related to the eviction lawsuit to be filed against him for breach of commitment.
4-Despite the warnings and notices, the defendant failed to comply with his written commitment. We request the eviction of the defendant from the leased property.
LEGAL GROUNDS: Law No. 6570 and Related Legislation
EVIDENCE: Lease Agreement, Notice, Commitment Letter
CONCLUSION: For the reasons stated, we request that the defendant be evicted from the leased property due to breach of commitment, that the costs of the proceedings be borne by the defendant, and that the opposing party’s attorney’s fees be awarded to us as attorneys, in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY