-SAMPLE PETITION-
ANKARA SENTRY ( ) TO THE COURT OF FIRST INSTANCE
THE REQUESTER
PLAINTIFF :A….. B….. (T.C.:…………….)
Address
LICENSE PLATE NO. :06 …
Attorney :
Address
DEFENDANTS : 1-CAUSE OF ACCIDENT
ISSUING DRIVER :C….. E….. (T.C.:……………)
2-CAR OWNER :E… D… (T.C.:…………)
LICENSE PLATE NO.:06 …
POLICY NO:…
3- X Fuse A.Sh.
The basis of the expenditure:… TL material compensation and … TL moral compensation
SUBJECT OF THE REQUEST: The vehicle with the license plate 06 … belonging to the client and the vehicle with the license plate 06 … belonging to the defendant E … D … the other defendant C….. While under the rule of D…, ../../…. It consists of material and moral compensation claims for the damage suffered by the client due to injury as a result of a traffic accident in which he was involved in his history.
descriptions
Plaintiff client A….. B….., 06 … Plate no …. October 2011) with the intermediary (a photocopy of the license is presented in the annex to the petition October-1)../../…. While moving towards Ostim from the direction of Batıkent on its history, your company has insured property E….. E….the one that belongs to 06 … Plate No …. Modelling …. Brand vehicle with other defendant C….. D…’s dominance while, ………. He was involved in a damaged traffic accident at the intersection.
C….. E….the vehicle under the direction and management of failed to stop, violating the speed limit rules of the location where the accident occurred, and quickly hit the vehicle under the direction and management of the client, causing the client to hit the vehicle in front, resulting in a chain injury traffic accident.
As a result of the incident, a Traffic Accident Detection Report (October-2) was kept. According to the defect report (tramer) issued in accordance with this report, the defendant C….. E….the vehicle with the license plate 06 … under the management of is the complete and original defective one.
The plaintiff client has no fault in this accident. The client was trapped in the vehicle and his right leg was broken. The client had to undergo surgery, after which he underwent physical therapy. The client had to cover the hospital and treatment expenses out of his own pocket. Invoices and documents related to these expenses are presented in October of this petition. (October-3)
The policy of the vehicle that caused the accident that caused the client to suffer this damage is Defendant X Insurance A.Sh. reviewed by. In accordance with the General Conditions of Compulsory Liability Insurance, the insurer, the insured 3.he is jointly and severally liable for the material and physical damages he has given to the persons, provided that he remains within the limits of the guarantee. The client was unable to work during the treatment process; he became temporarily incapacitated. However, since the loss of value realized as a result of the accident in the client’s vehicle also constitutes a material loss item from an economic point of view, it is necessary to compensate these losses directly by the insurance company. Again, the same law of 1429. According to the Article, the Insurer is obliged to compensate for the losses caused by the negligence of the policyholder, the insured, the beneficiary and the persons for whose actions they are legally responsible, if there is no contract to the contrary.
Although for this reason the defendant is attracted to the insurance company ../../…. Although a claim for material and moral compensation was made with the dated notice; the defendant insurance company left these claims of the client unanswered. For this reason, it has become necessary for us to go to the court case.
For all these reasons explained, we reserve the right to an excess to be determined after the determinations to be made by your court due to the accident; we demand that the client be paid financial compensation due to the loss of earnings caused by the inability to work with medical expenses as a result of the accident that occurred, and moral compensation due to the negative factors caused by the accident be calculated and paid to us.
LEGAL REASONS: KTK No. 6047, HMK, Law on Advocacy and other relevant legislation
PROOFS : Photocopy of the license of the vehicle, …/…/Dated 2021 ….. Accident Sequence Numbered Traffic Accident Detection Report, Invoices and documents related to treatment expenses, witness, expert and other all delail
CONCLUSION AND DEMAND: For all the reasons explained above; provided that we reserve the rights to sue and demand for excess;
1-As a result of the accident that occurred, the client’s hospital treatment expenses and loss of earnings caused by inability to work, as well as the damage and loss of value caused to the vehicle, for now … TL is the legal interest of our financial compensation claim to be collected from the defendants,
2-In order to reduce the sadness and pain experienced by the client due to the negative factors caused by the accident, the amount to be determined at the end of the trial for now … TL to collect moral compensation from the defendants,
3-We request by proxy that the decision be made to leave the trial expenses and the power of attorney fee to the defendants. 02.12.2021
PLAINTIFF A… B… ATTORNEY
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