TO THE COURT OF FIRST INSTANCE
CASE NUMBER: FIRST INSTANCE
CASE NUMBER:
DEFENDANT:
ATTORNEY:
CLAIMANT:
REPRESENTATIVE :
CASE : Compensatclient …………. is a specialist physician and, as a representative of an identity that upholds medical ethics and human relations, acted together with his wife as claimed by the plaintiff, in order to deceiveMy client …………. is a specialist physician and, as a representative of an identity that upholds medical ethics and human relations, acted together with his wife as claimed by the plaintiff, in order to deceive her by ……….They went to the court and filed a lawsuit against my client, demanding material and moral compensation, claiming that they had been deceived by certain documents and that this deception existed; Just as the claim lacks foundation, as we will explain below, there is no evidence to justify the claim for compensation, which will also be supported by documents, and in the light of our explanations below and the documents supporting these explanations, it will be seen that the claim for compensation is unfair and unwarranted.aim lacks foundation, as we will explain below, there is no evidence to justify the claim for compensation, which will also be supported by documents, and in the light of our eJust as the claim lacks foundation, as we will explain below, there is no evidence to justify the claim for compensation, which will also be supported by documents, and in the light of our explanations below and the documents supporting these explanations, it will be seen that the claim for compensation is unfair and unwarranted.
In other words;
1- In the plaintiff’s petition, it is as if my client and his wife were able to meet easily by providing a club membership for ……. and using the excuse of a match, as stated in the petition, ……..although he stated that he went to and met his wife here;
As can be seen in the attached document, my client attended a medical congress that was organized previously on the alleged ……… dates and, immediately after the end of the congress, he reserved a ticket due to his passion for football and went to the match in question as a spectators can be seen in the attached document, my client attended a medical congress that was organized previously on the alleged ……… dates and, immediately after the end of the congress, he reserved a ticket due to his passion for football and went to the match in question as a spectator. A document showing my client’s participation in the relevant medical congress and stating that he attended on the specified dates has been submitted.
2- Although the plaintiff used a statement in his petition as if his wife was residing in Turkey, the plaintiff’s wife is …2- Although the plaintiff used a statement in his petition as if his wife was residing in Turkey, the plaintiff’s wife is ……..according to what we have learned externally, because his parents reside in ……, in our opinion, we think it is natural for the plaintiff to show an address in Izmir province as well, since his wife is a citizen of the Republic of Turkey. This sentence has no defensible logic.
3-The fact that the plaintiff’s spouse obtained a protection order while the marriage was ongoing has no connection with my client. This issue is entirely related to the events that occurred between-The fact that the plaintiff’s spouse obtained a protection order while the marriage was ongoing has no connection with my client. This issue is entirely related to the events that occurred between the plaintiff and her spouse. If the plaintiff’s spouse has experienced any violence from his wife or has been subjected to psychological pressure, which, as the plaintiff also stated, there is also a divorce case filed in this regard. It is understood that the plaintiff’s wife felt the need to take a protection order, which she applied to the Family Court and took a decision on this issue. There is no aspect of this incident that can be related to the alleged action of my client.There is no aspect of this incident that can be related to the alleged action of my client.
4- The plaintiff has filed a lawsuit for moral compensation of ……… TL and material compensation of ……… TL from my client, claiming that he has suffered damage due to the deception of the spouses in accordance with the provisions of the Code of Obligations due to a breach of the fidelity obligation, but we believe that this request does not find a response in the law and the conditions are not met.
5-My client has never been to ………. Country during his life. As can be understood from the document we have presented, he went to attend a medical congress on the claimed dates-My client has never been to ………. Country during his life. As can be understood from the document we have presented, he went to attend a medical congress on the claimed dates of …….. He worked on this issue, despite the fact that the British administration imposed very difficult condent has never been to ………. Country during his life. As can be understood from the document we have presented, he went to attend a medical congress on the claimed dates of …….. He worked on this issue, despite the fact that the British administration imposed very difficult conditions, especially on the visa issue, he received his visa due to the fact that he is a doctor and the medical congress, and (….) with daily duration ………he must have gone to . In the meantime, my client, in the name of his passion for football and visiting historical places, has met the plaintiff’s wife, whom he had previously known in a humane framework, in order to ……….. In his phone call with , he specifically asked about what places can be visited in …………. and where he can go in a short timeIn his phone call with , he specifically asked about what places can be visited in …………. and where he can go in a short time, ………..he also made a phone call in the context of how and where he should go and with the guidance of the plaintiff’s wife ………’ he has visited the relevant places in the.
6-In both Civil Procedure and Criminal Procedure Law, the issues in question must be proven with material, definitive and convincing evidence. Where there is no evidence, material and moral damages cannot-In both Civil Procedure and Criminal Procedure Law, the issues in question must be proven with material, definitive and convincing evidence. Where there is no evidence, material and moral damages cannot be awarded. In this respect, the issues in the plaintiff’s petition have collapsed in the context of the documents and there is not even a response. There is no document, a photographic image, any information obtained through communication, documents showing the union of my client and the plaintiff’s spouse, proving their union and supporting their stay in any accommodation facility.
To put it on behalf of my client, we believe that the plaintiff resorted to slander in order to justify his own discontent and incompatibility with his wife and to strengthen his divorce case, and that he filed the case based on this as a reason. In additiono put it on behalf of my client, we believe that the plaintiff resorted to slander in order to justify his own discontent and incompatibility with his wife and to strengthen his divorce case, and that he filed the case based on this as a reason. In addition, my client ………….. who is definitely the plaintiff’s wife ………’ nin does not even go to the house where they live together, nor does he even know where he is.
These allegations are based only on interpretation, and perhaps in the plaintiff’s inner world, he filed a lawsuit for damages by subconsciously fictionalizing the humanitarian contribution that the plaintiff’s wife provided to my client in the context of such humanitarian assistance (club membership and ticket procurement), by giving into the idea that his wife was unfaithful, by directing slander at my client in a way that has no basis Jul.hese allegations are based only on interpretation, and perhaps in the plaintiff’s inner world, he filed a lawsuit for damages by subconsciously fictionalizing the humanitarian contribution that the plaintiff’s wife provided to my client in the context of such humanitarian assistance (club membership and ticket procurement), by giving into the idea that his wife was unfaithful, by directing slander at my client in a way that has no basis Jul.(As a result of the judicial process, we also state that we reserve the right to file a lawsuit against the plaintiff in connection with this.)
We wish that your Court will evaluate the documents showing the contrary, especially the alleged issues, whether the material and moral compensation conditions have been established, whether the plaintiff has earned the right to compensation, and come to a conclusion in the light of these documents.We wish that your Court will evaluate the documents showing the contrary, especially the alleged issues, whether the material and moral compensation conditions have been establishedWe wish that your Court will evaluate the documents showing the contrary, especially the alleged issues, whether the material and moral compensation conditions have been established, whether the plaintiff has earned the right to compensation, and come to a conclusion in the light of these documents.
In particular, it is known by your Court that a person has a “right not to be contaminated”, which is a universal rule of law, as in Civil cases and Criminal cases.
In this context;
As the distinguished jurist Sami Selçuk also stated in an article; (Milliyet Newspaper, 10.02.2009)
“… The suspect’s self-respect and honor should not be undermined. People who are thought to have committed crimes should not be hurt or tarnished. (The preliminary) investigation should never turn into a show of force… The suspect’s self-respect and honor should not be undermined. People who are thought to have committed crimes should not be hurt or tarnished. (The preliminary) investigation should never turn into a show of force.
…
Even being taken to an open trial hurts a person, even if they undermine … The suspect’s self-respect and honor should not be undermined. People who are thought to have committed crimes should not be hurt or tarnished. (The preliminary) investigation should never turn into a show of force.
…
Even being taken to an open trial hurts a person, even if they undermine their self-esteem. For this reason, some countries have also adopted an appeal method against the process (indictment or decision to open a final investigation) that initiated a lawsuit before it was brought to open trial. The fact that we do not have such a way cannot be an excuse for undermining people’s self-esteem, of course…
…
Moreover, the exercise of authority can be beautiful. It can also be ugly. One should not choose the ugly when there is the beautiful. It can be moderate or strictoreover, the exercise of authority can be beautiful. It can also be ugly. One should not choose the ugly when there is the beautiful. It can be moderate or strict, one should not choose the strict when there is the moderate. Since the Roman law, the principles by which humanity has reached experiences must be followed. ‘Rigidity is very close to injustice, and no one can be deprived of legal protection/justice’…”
The plaintiff has again made unfounded statements about my client, and not only is there no evidence for these statements, but it is understood that he resorted to this method in order to create a reason for his incompatibility with his wife and the divorce case he filed.as again made unfounded statements about my client, and not only is there no evidence for these statements, but it is understood that he resorted to this method in order to create a reason for his incompatibility with his wife and the divorce case he filed. Moreover, the plaintiff and the defendant’s marital relationship has ended and the plaintiff had a protection order issued against her by her husband long before the alleged events. My client’s acquaintance with the plaintiff’s husband is an acquaintance that remains within humane limits.
In order to support our statements in question, we present each document that we have opened below to the appreciation and evaluation of your Court.
In this context;
a order to support our statements in question, we present each document that we have opened below to the appreciation and evaluation of your Court.
In this context;
a-) “………..” My client’s ………. pIn order to support our statements in question, we present each document that we have opened below to the appreciation and evaluation of your Court.
In this context;
a-) “………..” My client’…. proving the call in relation to the medical cIn order to support our statements in question, we present each document that we have opened below to the appreciation and evaluation of your Court.
In this context;
a-) “………..” My client’s ………. proving the call in relation to the medical congress in its history “………. a photocopy of the invitation to attend the medical congress called ”The latest developments in cancers”.
b-) Photocopy of the flight ticket showing the travel to and from the congress on the dates in question.
c-) Reference information regarding the promotion of the congress in line with its purpose. . The document is a document showing the program content and ………..it belongs to their history.
d-) In the same way, following the date of ………., my client played the following day-) In the same way, following the date of ………., my client played the following day in ……… ………….. he attended the match and because of my client’s passion for football, he wants to go to the match that will be played after the end of the congress days, and in this context, because club membership is required to make a reservation, the inf the same way, following the date of ………., my client played the following day in ……… ………….. he attended the match and because of my client’s passion for football, he wants to go to the match that will be played after the end of the congress days, and in this context, because club membership is required to make a reservation, the information house showing Arsenal club membership (Match tickets) and the method of ticket purchase. This document was taken from the website of ……… club. However, the document showing the club membership was torn up and destroyed by the plaintiff.
The way this incident occurred was as follows.
My Client ………….. on one occasion in the framework of humanitarian friendship, the plaintiff’s wife has lived in England for many years and knows this country very well, because she will attend the medical congress on the aforementioned dates, and at the end of the congress, she told the plaintiff’s wife that she wanted to participate in the match in question, that she needed a membership to get tickets for this match, that is, to book, she asked her to help in this context, the plaintiff’s wife also conveyed her wish to help in a humanitarian framework Jul, In the process that developed when Arsenal settled the club membership, the plaintiff’s wife left her home where she was staying in London and came to Turkey because her parents were in her diary, meanwhile, the plaintiff, who was ready to leave the house because she stayed at her house in England on her tickets, saw the ticket and the card showing the club membership when she Decanted all the belongings belonging to the house with her cousin and left, and tore up the ticket and destroyed the club membership card.
The plaintiff’s wife ………’ after you returned to the apartment, you saw that the belongings were taken away, your wife left the house, the house was left disheveled, and the club membership card and ticket she bought for the defendant were torn up here, the plaintiff’s wife applied to the police because of this painting she saw, applied for detection because the house was evacuated.
In this case, my client ………… English speaking, my client knew English to express himself and explained that he was a doctor and came from abroad, although they stated that he could maybe go to the match, he went to the stadium where the match was being played again, that he did not have a membership card, so he could not enter the match, again he did not even have a ticket, but by the way, he wanted to participate in the match, the officials here were tolerant and provided the opportunity to watch the match by picking up my client at the stadium not from where the normal spectators came, but from where the football players entered. He did not have a membership card, so he could not enter the match, but by explaining that he did not have a ticket, by the way, by the way, he knew English to express himself Decently and that he was a doctor and from abroad.
Participation and invitation of my client to the congress in question in the context of the documents ………. The text of the invitation made by the pharmaceutical company related to this, the call letter written in Turkish text is presented.
In addition ……… accommodation expenses between the dates of congress attendance and plane tickets……………… Dec….articipation and invitation of my client to the congress in question in the context of the documents ………. The text of the invitation made by the pharmaceutical company related to this, the call letter written in Tuarticipation and invitation of my client to the congress in question in the context of the documents ………. The text of the invitation made by the pharmaceutical company related to this, the call letter written in Turkish text is presented.
In addition ……… accommodation expenses between the dates of congress attendance and plane tickets……………… Dec…. ………. the document bearing the title and the document showing that the bed and breakfast were paid for were also presented separately.
The document showing the flight times showing the departure and return of my client,
……….. a document stating that the payments have been met by the company,
Again, a document bearing the title “Pre-Pait Accommodation” indicating that the reservation has been made and payments have been made has been submitted.
A document showing the hotel location, as well as a document showing that my client stayed at the hotelAgain, a document bearing the title “Pre-Pait Accommodation” indicating that the reservation has been made and payments have been made has been submitted.
A document showing the hotel location, as well as a document showing that my client stayed at the hotel,
Conclusion an a document bearing the title “Pre-Pai