…… TO THE HONORABLE COURT
Request for Provisional Measures
……
PLAINTIFF: …….
ATTORNEYS: …….
DEFENDANTS: …….
SUBJECT: Subject to our right to claim and sue for excess, our request for the joint and several collection of ……. in material damages from the defendants, with legal interest from the date of the accident, and for a provisional measure to be placed on the registration of the vehicle with license plate number ……. to secure our claim.
EXPLANATIONS: 1-Our client ….. ……, the registered owner of the vehicle with license plate number .. .. …. and the defendants …. ……, the driver, and …. ….., the owner of the vehicle with license plate number .. … .., were involved in a traffic accident on ../../…. that resulted in material damage, death, and injury.
2-The incident occurred on ……. at approximately ……. when the vehicle with license plate number ……. ……. crossed into the opposite lane and collided with our client’s vehicle. As can be seen from the Traffic Accident Report, the other party is primarily at fault in this incident. They crossed into the opposite lane and collided with the vehicle owned by our client.
3-As a result of this accident, the vehicle with license plate number ……. owned by our client was damaged beyond repair. Our actual damages will be determined as a result of the assessment we had conducted with the ……. Civil Court of First Instance ……. D. İş.
LEGAL GROUNDS: Traffic Law, Code of Civil Procedure, Relevant Legislation
EVIDENCE:
Traffic Accident Report,
Traffic Records
Investigation and Expert Examination
……. ACM ../…. E. File No.
……. AHM ../…. D. Case File
Witness Statements,
Legal and Discretionary Other Evidence, etc.
RESPONSE PERIOD: 10 Days
RESULT OF THE REQUEST : For the reasons stated, subject to our right to claim and sue for excess amounts, to jointly and severally collect ……. material compensation from the defendants with legal interest from the date of the accident, to charge the defendants with the costs of the proceedings, to place a precautionary measure on the registration of the vehicle with license plate number ……. to secure our claim, Pursuant to the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667, we request that the opposing party’s attorney’s fees be awarded to us as attorneys.
PLAINTIFF’S ATTORNEY