COURT OF FIRST INSTANCE
THE PLAINTIFF :
ATTORNEY :
DEFENDANT : Ministry of Interior
SUBJECT OF THE CASE : Compensation (…… TL).
FACTS : 1- The plaintiff client is registered in …………. province, …………… district, Volume No: …………, S.No: …………….., married to his wife …………….. in ……… and has three children from this marriage, …. years old …… … years old ……… and … years old ………
2- While the client was working as a labourer at ………., he normally received child allowances from the birth of each child. However, during the computerisation of the population records, somehow the records of the client’s children disappeared and the client was shown as childless.
3- In order to receive child allowance at ………., population records must be submitted at the beginning of each year. When the client requested the population record for the year ….., he saw that his children were not written in the records given, and upon his objection, they told him that his records were transferred in this way, but that it was possible to correct it by filing a lawsuit.
4- The client could not receive the child allowance for the period until the lawsuit was filed and corrected, and therefore suffered financial damage. This damage is approximately the amount of the lawsuit ….. … TL, which is the amount of the lawsuit.
It has become compulsory to file this lawsuit for the compensation of the material damage suffered.
LEGAL GROUNDS :
EVIDENCE : Old and new population records, birth certificates of the children, witness statements, translation of the foreign records showing that the client receives child allowance, expert examination and all kinds of legal evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, our lawsuit is accepted and …….. We respectfully request and demand that the defendant be ordered to collect the financial compensation of TL from the defendant together with the highest commercial interest from the date of ………….., which is the beginning of the damage, to reserve our right to demand more, and to impose the costs and attorney fees on the defendant…/…/….
Plaintiff Representative
Hunting………………….
(SIGNATURE)
ANNEX: