TO THE COMMERCIAL COURT OF FIRST INSTANCE
THE PLAINTIFFS :
ATTORNEY :
THE DEFENDANTS :
Lawsuit : Due to bodily harm in a traffic accident, it is the request of the defendant insurance company to be decided to be collected from the defendant insurance company together with the interest to be operated from the default date, trial expenses and attorney’s fees, not exceeding the insurance limit on the date of the event, by calculating compensation according to the evidence to be collected in accordance with …………..
The value based on the fee : ………. TL
Explanations
1-In the traffic accident that occurred near ……………… on ………… at around …….. on the day of …….., the driver of the ……….-plate pickup truck ………., as a result of seeing the curve too fast, lost control of the steering wheel, entered the opposite lane and overturned, and in the meantime, hit the ………-plate car under the direction of ………., which was travelling in the opposite lane, causing severe injury to …………, who was a passenger in the pickup truck, and he died. (The accident report and the decision of the C.Prosecutor’s Office non-prosecution due to the death of the driver are attached.)
2-According to the traffic accident report and the explanations in the non-prosecution file of ……….C.Prosecutor’s Office ………. day ………. main ………. decision numbered ………, it is concluded that the deceased driver ………. of the pick-up truck with ……….. plate was 100% at fault in the occurrence of the accident, and that the other vehicle driver travelling in his lane and the plaintiff ………., who was a passenger in the pick-up truck with ………. plate during the accident, had no fault. (……… C.Prosecutor’s Office ………)
3-…….. Training and Research Hospital …….. According to the report of the Health Board ……… day ……… no………., the rate of loss of physical strength of the plaintiff ………. d.lu ……… is ……% (The report is attached.)
4- Since our lawsuit has been filed as an “indefinite receivable lawsuit” according to the article ………, according to the evidence to be collected during the trial, the examinations to be made by the court and the report to be obtained from the calculation expert whose expertise in the field of compensation law is known, we request that the amount of compensation to be determined definitively be decided to be collected from the defendant together with the interest to be operated from the date of default, not exceeding the insurance limit on the date of the incident, after the fee is paid. (The plaintiff’s population record, occupational certificate.)
5- Since the vehicle with …….. licence plate causing the accident was insured to the defendant Insurance Company with the policy numbered …….. valid between ………… and …………, financial compensation up to the limit and (since no positive result was obtained despite the application made before the lawsuit) ……… interest to be operated from the default date. (Insurance policy, application letter and response.)
Legal Reasons :
Evidence : Accident reports, traffic and insurance records, C.Prosecutor’s Office decision of non-prosecution, Health Board Report on the loss of physical strength of the plaintiff, application letter and response to the insurance company, etc. all kinds of evidence.
Conclusion and request : For the reasons presented:
In accordance with ……… due to bodily harm in a traffic accident, we respectfully request and demand that the defendant insurance company be decided to be collected from the defendant insurance company together with the interest to be operated from the default date, trial expenses and attorney’s fees, not exceeding the insurance limit on the date of the incident, by making a compensation calculation according to the evidence to be collected. ../../..
Plaintiff Attorney
Add :
Attorney. ………..
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