……. TO THE HONORABLE COURT
…….
PLAINTIFF:
ATTORNEY:
DEFENDANTS:
SUBJECT: ………………….-TL, along with bank discount interest, expenses, and attorney fees, is requested to be collected from the payment date of .. / .. / ….
FACTS: 1-The premises insured under insurance policy no. ……………… in the name of ………………………………………………………………………………………… at our company suffered damage as a result of a fire that broke out at the defendant’s workplace on .. / .. / ….
2-The damage compensation of ………………………-TL determined as a result of the expert assessment carried out at the insured location has been paid to our insured.
3-With the payment of the damage, in accordance with the terms of the contract and the provisions of Article 1301 of the Commercial Code, our company has become the successor to the insured and all rights against those who caused the damage to the insured have been transferred to our company.
4-According to the minutes and expert report prepared regarding the incident, the defendant has been determined to be responsible for the damage that occurred. Since the defendant is liable to our insured and, consequently, to our Company acting on his behalf, it has become necessary to file this lawsuit.
LEGAL GROUNDS: HUMK, BK, TTK, Traffic Law, and relevant legislation provisions.
EVIDENCE: Policy, investigation report, expert examination, and all types of legal evidence.
RESPONSE PERIOD: 10 days
CONCLUSION AND REQUEST: As stated above, we request that the Parties be notified and that, as a result of our case being proven, the Defendant be ordered to pay ……………………………-TL, together with bank discount interest, expenses, and attorney’s fees, from the payment date of .. / .. / ….
Plaintiff’s Attorney