TO THE PRESIDENCY OF THE ADMINISTRATIVE COURT OF …..
PLAINTIFF: (Turkish Republic Identity Number):
ADDRESS:
REPRESENTATIVE:
ADDRESS:
DEFENDANT:
SUBJECT: Submission of our petition requesting compensation for damages incurred due to a terrorist act under Law No. 5233.
OUR EXPLANATIONS
1-) Our client was injured on …/…/… while in a coffeehouse in …. District, …. Village, …. Province, as a result of unidentified individuals opening fire with an automatic weapon.
2-) Our application for compensation for the damages incurred due to the injury, in accordance with Law No. 5233, was evaluated by the Damage Assessment Commission of the …. Province Governorship, and as a result of this evaluation, a draft settlement agreement was presented to our client for a payment of …. TL. However, since our client did not accept this draft, it has become necessary to file this lawsuit with this petition, seeking the annulment of the dispute report dated …/…/… and compensation for the loss of earning capacity and treatment expenses of … TL incurred due to the incident.
3-) Our client was hospitalized for treatment due to the incident and was unable to work for … days. Therefore, compensation for the material damages of … TL is required.
4-) For the reasons we have tried to explain above, it has become necessary for us to file a lawsuit within the legal period to annul the dispute report and to claim compensation for the damages incurred.
LEGAL GROUNDS: Law No. 5233, Articles 4, 5, 6, 7, 9; Law No. 2577, Article 15;
Regulation on Compensation for Damages Arising from Terrorism and the Fight Against Terrorism, Article… 15, 16, 17
LEGAL EVIDENCE:
1) Application letter to the Governor’s Office dated …/…/…
2) Governor’s Office dispute report dated …/…/…
3) Hospital records
4) All other relevant legal evidence.
CONCLUSION AND REQUEST: For the reasons explained above, we hereby request, on behalf of our client, that the decision of the … Province Governor’s Office dated …/…/… and numbered … be annulled with respect to our client, that …. TL. compensation be awarded with interest to be calculated from …/…/…, and that the court costs and attorney’s fees be borne by the opposing party. …/…/…
ATTACHMENTS: 1) Application letter to the Governor’s Office dated …/…/…
2) Governor’s Office dispute report dated …/…/…
3) Hospital records
4) Certified copy of the power of attorney.
Plaintiff’s Attorney
Attorney
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