COURT OF FIRST INSTANCE
DEFENDANT :
DEFENDANT :
SUBJECT OF THE CASE : Material-Material Compensation due to Attack on Personal Rights ……. TL.
FACTS : 1- The plaintiff client is a well-known doctor who is loved and respected in his environment, whose success is appreciated and has a high customer potential.
2- The defendant is a patient who has a good financial situation and comes to the plaintiff for examination and treatment. After the examination on ……………, he started an argument and incident for the visit fee, despite all the good intentions of the doctor, he continued the discussion and brought it to the attack stage, attacked the client by swearing and insulting in front of other customers and damaged his professional tools. A criminal case has been filed against him.
3- As can be seen in the determination file attached, the total damage to the tools is ……. TL.
4- Due to these attacks and insults. The client, who is embarrassed towards other customers and the environment and deeply regrets this situation, is also ……. TL for non-pecuniary damages.
LEGAL GROUNDS :
EVIDENCE : ……. As. Criminal Court’s . ….. sy. file, detection file, witnesses, expert examination and all kinds of legal evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above. Our lawsuit is accepted and ……. TL pecuniary, …….. TL pecuniary and …….. TL non-pecuniary, totalling …….. TL from the defendant with interest. From the date of the incident ………….., I wish that our right to more is reserved and that the costs and attorney fees be decided to belong to the defendant.
I would like to submit. Sincerely yours.
Plaintiff’s Counsel
Av………………….
(SIGNATURE)
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