-SAMPLE PETITION-
TO THE ANKARA ON-DUTY CIVIL COURT OF FIRST INSTANCE
REQUESTOR :A….. B….. (T.C.:…………….)
Address
Attorney :
Address
MURIS :E…. B…. (T.C.:…………….)
LICENSE PLATE NO. :06 …
ACCIDENT
THE GIVER :C….. E….. (T.C.:……………)
LICENSE PLATE NO. :06 …
CASE VALUE :……………………. TL
SUBJECT OF THE REQUEST: Murise’s 06 … license plate vehicle and the defendant C….. E….. your car with the license plate 06 … belongs to ../../…. It consists of our material and moral compensation claims for the damage suffered by the client, who is the heir, due to the loss of life of E … B … as a result of a traffic accident in which he was involved in his history.
descriptions
Muris E….. B….., 06 … Plate no …. October 2011) with the intermediary (a photocopy of the license is presented in the annex to the petition October-1)../../…. In its history, while moving towards Ostim from the direction of Batıkent, its property C….. E….the one that belongs to 06 … Plate No …. Modelling …. Brand tool, ……………………. He was involved in a traffic accident at the junction.
C….. E….‘s conduct in the vehicle, the location of the accident in violation of the rules and the speed limit of the vehicle speed by multiplying stand in the conduct of the client, the client have caused it to crash into the vehicle in front, and thus, an accident occurred. E….. B….. he was stuck in the vehicle; he was removed from the vehicle by paramedics who arrived at the scene of the incident and was transported to the hospital by ambulance. Despite all the interventions made in the hospital, E… B… could not be saved.
As a result of the incident, a Traffic Accident Detection Report (October-2) was kept with the police teams who arrived at the scene. According to the defect report (tramer) issued in accordance with this record, C….. E….the vehicle with the license plate of 06 … is the complete and original defective one. Murisin has no fault in this accident.
As October 3, the petition attached to the inheritance decision we have presented, as it can be understood, the client who makes the request is the sole heir of the muris. October 3, the application is submitted to the Court of appeal. Mur October who lost his life in this way (mur October’s credentials are presented in the annex to the petition Annex-4) the hospital and burial costs of the client had to cover out of his own pocket. Invoices and documents related to these expenses are presented in October of this petition. (October-5)
However, the client was not working and the client’s father muris E… B… was providing his livelihood. With the death of Murisin, the client was deprived of the financial support that Murisin provided to him. In addition to the sadness and grief he experienced with the death of his father, he also fell into financial difficulties in this way.
Ankara … Criminal Court of First Instance 2021 / … C…. which caused the death of the client’s father with the main numbered file….. E…. October 6 October a public case (the indictment is attached) has been opened against him and the trial is continuing. Until the defect rates are determined by this criminal case and the expert examination to be carried out by the civil court, our rights regarding the surplus are to be reserved; occurring as a result of an accident, your client bereft of support, and value Muris hospital treatment expenses and burial expenses due to the damage to the vehicle with financial compensation for the loss of TL due to the negative factors of the accident and… now my client experienced sadness and TL elimination… for now in the name of reducing the amount of non-pecuniary damages to be paid by the defendant is taken from us and demand.
LEGAL REASONS: KTK No. 6047, HMK, Law on Advocacy and other relevant legislation
PROOFS : Photocopy of the license of the vehicle, …/…/Dated 2021 ….. A traffic accident report accident sequence number, probate, notice Muris the credentials of the hospital and burial expenses invoices and documents for Chinese criminal court, 2021/ all main file and numbered delail the poet…
CONCLUSION AND DEMAND: For all the reasons explained above; without prejudice to our rights of demand for excess;
1- The support that the client was deprived of as a result of the accident, murisin hospital treatment expenses and burial expenses, 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 defendant,
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 defendant,
3-We request by proxy that the decision be made to leave the trial expenses and the power of attorney fee to the defendant. 01.12.2021
PLAINTIFF A… B… ATTORNEY
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