……. TO THE HONOURABLE JUDGE
Precautionary Measure Requested
…….
THE PLAINTIFF :…….
DEFENDANTS :…….
DEFENDANTS :…….
SUBJECT : Without prejudice to our right to claim and sue for the excess, our request for the collection of ……. financial compensation from the defendants jointly and severally together with the legal interest from the date of the accident, and our request for an interim injunction to be placed on the registration of the vehicle with the number plate ……. in order to secure our receivable
EXPLANATIONS :1-Our client ….. ……, the registered owner of ……, and the vehicle with the number plate … … …., the driver of the defendant …. …… and the owner of …. ….., and the vehicle with the number plate … … …, the driver of …. …… and the owner of …. ….., had a traffic accident with material damage, death and injury on ../../…..
2-The incident happened on the day of ……. around ……. ……. ……. Plate numbered vehicle entered the opposite lane and hit the vehicle belonging to our client. As can be understood from the Traffic Accident Detection Report, the other party is the main defect in the incident. By violating the lane, he hit the vehicle owned by our client.
3- Due to this accident. The vehicle ……. with the number plate ……., which is owned by our client, has been damaged beyond repair. ……. Civil Court of First Instance ……. D. Our real damage. Will be revealed as a result of the determination we have made with the work.
LEGAL GROUNDS : Traffic Law, HUMK, Related Legislation
EVIDENCE :
Traffic Accident Report,
Traffic Records
Discovery and Expert Review
……. ACM ../…. File No. E.
……. AHM ../…. D.Work File
Witness Statements,
Other Legal and Discretionary Evidence etc.
RESPONSE TIME : 10 days
CONCLUSION OF THE REQUEST : For the reasons stated above, without prejudice to our right to claim and sue for more, we request that the ……. financial compensation be collected. Jointly and severally from the defendants together with the legal interest from the date of the accident. That the judicial expenses be charged to the defendants, that the registration of the vehicle. With the number plate ……. be put under injunction in order to secure our receivable, and that the counterparty. Attorney fee be awarded on our behalf as a lawyer in accordance. With the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
…….
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