Eviction Case Due To Construction
…….TO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Eviction Due to Reconstruction
VALUE OF CLAIM: Annual Rent Amount …….
EXPLANATIONS: 1-The Defendant is our client’s tenant. They reside in the two-story wooden house located at ……. belonging to our client, under a written lease agreement dated ……. and pay a monthly rent of …….
2-Our client will demolish the building in question and construct a new building in its place. The project work for the building to be constructed has been completed, the necessary applications have been made, and the building permit has been obtained.
3-This situation has been notified to the tenant in accordance with Article 7/c of Law No. 6570 by means of a notice dated ……. and numbered ……. issued by the ……. Notary Public. Despite this, the defendant tenant has not vacated the property.
Therefore, we request the eviction of the tenant from the property.
LEGAL GROUNDS: Law No. 6570 and Related Legislation
EVIDENCE: Lease Agreement, Notice, Project, Construction Permit.
CONCLUSION: For the reasons stated above, we request that the defendant be evicted from the leased property due to reconstruction, 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