ISTANBUL ……. TO THE HONOURABLE JUDGE OF THE CIVIL COURT OF FIRST INSTANCE
FILE NO: 2013/………. Basis
RESPONDENT (DEFENDANT):
DEFENDANT: Av.
DEFENDANT:
SUBJECT: It consists of submitting our response to the lawsuit.
EXPLANATIONS
1.) First of all, we file a COMPLAINT for the case before us. As it is understood from the statement of claim, the plaintiff has filed a lawsuit against the client. Company for the same damage in Istanbul …. The plaintiff filed a lawsuit against the client company for the same damage through the file numbered. 2013/………… Esas of the Istanbul Civil Court of First Instance. It is not in accordance with the rules of law for the plaintiff to file a new lawsuit for the same damage. Moreover. The damage arising as a result of the traffic accident is not in accordance with Istanbul ….. will be determined and judged in the case numbered 2013/………… Esas of the Istanbul Civil Court of First Instance. For this reason, the plaintiff has no legal interest in filing this lawsuit.
2.)In addition, the plaintiff has agreed. With ………………… Sigorta A.Ş., where the vehicle belonging. To the client company is insured………………………….. TL subject to the lawsuit, and that they were given a day for payment. By the insurance company, and then the defendant insurance company stated. That the payment was not made by the defendant insurance company. Because our driver, an employee of the client company, was found to be at fault. For some reason, the manner of occurrence of the traffic accident. Subject to the lawsuit was not explained by the plaintiff’s attorney. The vehicle belonging to the client company. Was hit from behind by a lorry whose licence plate was not taken, and in the traffic accident report.
It was accused of committing the offence of hitting from behind. Among the primary defects numbered 04, and the 34 AA 0000 plate vehicle under. The management of the plaintiff hit the vehicle belonging. To the client company from behind. However, it was stated in the report that the plaintiff did not commit the offence of rear-end collision, but committed.
The offence of sleepless, tired and distracted. Driving among the secondary defects. The application of different penalties for the same offence damages the reliability of the traffic accident report. The plaintiff is at fault. Stopped vehicle is the vehicle belonging to the client company. However, the plaintiff was travelling at high speed and disregarded. The traffic rules. The accident occurred because the plaintiff did not maintain the required cruising distance between the vehicles.
CONCLUSION and REQUEST. For the reasons presented and explained above. We request that our objection to the pendency. Of the case be accepted, and if not. The unfair and groundless lawsuit be dismissed. On the merits, and the trial expenses and attorney’s fees be decided to be charged to the other party.
Defendant Attorney
You can access our other article examples and petition examples by clicking here.