TO THE HONORABLE COURT
PLAINTIFF:
ATTORNEY:
DEFENDANTS:
SUBJECT:……………………………………..-TL from .. / .. / …. payment date, …………………………-TL from .. / .. / …. payment date (Total ……………………….-TL, subject to our reserved rights to claim any excess) bank discount interest, expenses, attorney’s fees, and collection request.
FACTS: 1-A theft occurred on .. / .. / …. at the insured workplace under the name of …………………………………………. with insurance policy number ……………… held by our company.
2-The defendant ………………………….. committed the act, and ………… ………….. caused our client to suffer damage by failing to properly care for and supervise the minor ( ……….. …………….. ) under his guardianship. A lawsuit was filed against our company and the defendants by our insured ………………… at the ……………. Civil Court of First Instance on ……./…… E. Number, and in relation to the concluded case, …………………-TL was deposited into file number ……. on 04.07.2002, and a total of …………………-TL was paid to our insured on 21.07.2000.
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 our insured and all existing rights against those who caused the insured’s damage have been transferred to our company.
4-According to the minutes drawn up regarding the incident and the Court Decision, the defendants have been determined to be responsible for the incident. Since the defendants are 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, ……………… Civil Court of First Instance’s 2000/503 E., ……./……. K numbered judgment, 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 successful lawsuit, ………………………………………-TL be paid on 04.07.2002, and …………………………… -L on 21.07.2000 (with our rights to claim the total amount of …………………….-TL in excess reserved) together with bank discount interest, expenses, and attorney’s fees from the defendants. …….
Plaintiff’s Attorney