ANKARA PUBLIC PROSECUTOR’S OFFICE
THE COMPLAINANT
CLIENT : A….. B….. (I.D. No.:…………)
ADDRESS :………………………………..
ATTORNEY :
ADRESS :
PHONE :
RESPONDENT
SUSPECT : 06 … The driver of the vehicle with license plate number
SUBJECT OF COMPLAINT : :../../…. It is about our request to identify the suspect who escaped without being recorded after a traffic accident that occurred on his date and our complaint about him.
Instructions
Plaintiff client A….. B….., 06… Plate No…. October 1) The vehicle (a photocopy of the license is presented in the october of the petition)../../…. 06 … License plate number belonging to the suspect as he was driving towards Ostim from the direction of Batıkent in the history of , ……………………. He was involved in a traffic accident with property damage at the intersection.
In the conduct of the suspect vehicle, the location of the accident in violation of the rules and the speed limit of the vehicle speed by multiplying stand in the conduct of the client, the client was caused to crash into the vehicle in front and thus a pileup occurred.
As a result of the incident, the client wanted to keep a Traffic Accident Detection Record and got out of his vehicle on this occasion, but the suspect continued to drive his vehicle and escaped without keeping the record. The suspect has not been identified because he did not get out of his vehicle and fled. However, at the time of the incident, the client received the license plate of the vehicle.
Since the incident was a chain accident and there was a crowded street, many people witnessed the incident and the information of the witnesses was given in our petition. In addition, there are mobile phones and shop cameras in the place overlooking the crime scene, and we are requesting a subpoena of these camera records.
After that, the client complained about the incident to the Yenimahalle District Police Department and a Traffic Accident Detection Report (ANNEX-3) was kept here. It is also fixed by this record that the driver of the car we complained about and escaped from is fundamentally flawed in the incident.
According to the defect report (tramer) issued in accordance with this report, the vehicle with the license plate number 06 … belonging to the suspect is fully defective. The suspect caused the accident by violating Articles 52/1-a and b of the Road Traffic Code No. 2918. According to these articles, “Drivers:
a) Reducing their speed when approaching intersections, entering turns, approaching hill tops, moving along turnpike roads, approaching pedestrian crossings, level crossings, tunnels, narrow bridges and culverts, entering construction and repair areas,
b) They must match their speed to the load and technical characteristics of the vehicle they are using, the conditions required by visibility, road, air and traffic conditions.”
Due to this accident, there are major damages to the vehicle 06 … License plate number belonging to our client. The client’s vehicle, which has become unusable, is still …….. Ostim Yenimahalle is located at the address of Ankara …. It is located in the Auto Repair Shop.
We are complaining about the victimization of the client caused by the accident in which the driver of the vehicle with the license plate number 06 caused the accident and then fled without even keeping a record. We also reserve the right to any material and moral compensation that we will request from him after the identification of this person.
LEGAL REASONS: KTK, HMK, Law on Advocacy No. 6047 and other relevant legislation
EVIDENCE: A photocopy of the vehicle’s license, photos of the vehicles involved in the incident and the client’s vehicle after the accident, a subpoena of mobile phone and shop camera records, kept at the Yenimahalle District Police Department …/…/Dated 2021 ….. Accident Sequence Number is a Record of the Determination of a Traffic Accident with Material Damage, witnesses, expert witnesses, reconnaissance and other all delail
CONCLUSION AND REQUEST: For all the reasons described above, we offer and request by proxy that a public lawsuit be filed to punish the driver of vehicle 06 … License plate number that crashed into the client’s vehicle and fled. 25/11/2021
The Complainant Who Filed The Complaint
Attorney