COURT OF FIRST INSTANCE
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : Non-pecuniary damages for infringement of the right to name.
FACTS : 1- The plaintiff is a well-known, popular and respected writer with his client’s name and serious literary works.
2- The defendant, although his real name is different, published a book under the name of the client in order to benefit from the reputation of the client and the circulation of his books. Upon the publication of the book, news was made against the client in various newspapers, it was mentioned that he had lost his reputation and caused a great reaction. This situation also caused the client great pain and anguish.
3- In addition to the material damage caused to the plaintiff. It is obvious that the honour and dignity of the client has been played with and the author has been hurt and his professional career has been damaged morally.
For these reasons, it has become compulsory to file this lawsuit for non-pecuniary damages.
LEGAL GROUNDS :
EVIDENCE : Published books, newspaper clippings. Witness statements and all kinds of evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above. With the acceptance of our lawsuit, …….. TL non-pecuniary damages with interest from the date of. The defendant’s publication of the book, and the costs and attorney fees to be charged to the defendant.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
Lawyer………………….
(SIGNATURE)
ANNEX: Power of Attorney.
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