Complaint Petition For Accident And Fleeing Car Driver
TO ANKARA PUBLIC PROSECUTOR’S OFFICE
COMPLAINANT
CLIENT :A….. B….. (T.C.:…………)
ADDRESS
AGENT :Lawyer …………
ADDRESS
COMPLAINTED
PUNISHER : Driver of the vehicle with the licence plate number 06 …
SUBJECT OF COMPLAINT :
…/../…. It is about our request to identify the identity of the suspect who fled before the report could be kept after the traffic accident that occurred on the date and our complaint about him.
EXPLANATIONS
Plaintiff client A….. B….., …. with the licence plate number 06 … Vehicle (copy of the licence plate is attached to the petition as Annex-1) and ../../…. While travelling towards Ostim from the direction of Batıkent on the date of …/…/……………………., he was involved in a collision with the vehicle with the number plate 06 … belonging to the suspect, ……………………. Intersection with material damage traffic accident.
The vehicle driven and managed by the suspect could not stop by violating the speed limit rules of the location where the accident occurred and hit the vehicle driven and managed by the client at high speed, causing the client to hit the vehicle in front and thus a chain accident occurred.
As a result of the incident, the client wanted to keep a Traffic Accident Report and got out of his vehicle on this occasion, but the suspect continued to drive his vehicle and fled before the report was kept. Since the suspect did not get out of his vehicle and fled, his identity could not be determined. However, the client took the licence plate number of the vehicle at the time of the incident.
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Since the incident was a chain accident and it was a crowded street, many people witnessed the incident and the information of the witnesses is given in our petition. In addition, there are mobese and shop cameras at the place overlooking the scene of the incident, and we request the subpoena of the camera records in question.
Subsequently, the client filed a complaint at the Yenimahalle District Police Department, where a Traffic Accident Report (Annex-3) was kept. It is evident from this report that the driver of the vehicle we filed a complaint against and the driver of the fleeing vehicle was at fault in the incident.
According to the defect report (tramer) issued in accordance with this report, the 06 … plate vehicle belonging to the suspect is fully at fault. The suspect caused the accident in question by violating Articles 52/1-a and b of the Road Traffic Law No. 2918. According to these articles, “Drivers:
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a) Reduce their speed when approaching junctions, entering roundabouts, approaching hill tops, travelling on winding roads, approaching pedestrian crossings, level crossings, tunnels, narrow bridges and culverts, entering construction and repair areas,
b) They are obliged to adapt their speed to the load and technical characteristics of the vehicle they are driving and to the conditions required by the visibility, road, weather and traffic situation.”
As a result of this accident, the client’s vehicle with the licence plate number 06 … has suffered major damages. The client’s vehicle, which has become unusable, is still …….. …. located in Ostim Yenimahalle Ankara Auto Repair Shop located at Ostim Yenahahalle Ankara.
We file a complaint against the driver of the vehicle with the number plate 06 … who caused the accident due to the victimisation of the client as a result of the accident that he caused and then fled before a report could be filed. We also reserve our rights to all kinds of material and moral compensation that we will demand from him after the identity of this person is determined.
LEGAL GROUNDS :
6047 numbered KTK, HMK, Attorneyship Law and other relevant legislation
EVIDENCE : Photocopy of the vehicle’s licence, photographs of the vehicles involved in the accident and the client’s vehicle after the accident, subpoena of mobese and shop camera records, ….. dated …/…/2021 kept at Yenimahalle District Police Department Accident Sequence Numbered Material Damaged Traffic Accident Report, witness, expert, discovery and all other evidence
CONCLUSION AND REQUEST:
For all the reasons explained above, we hereby request and demand by proxy that a public lawsuit be filed for the punishment of the driver of the vehicle with the number plate 06 … who hit the client’s vehicle and fled. 25/11/2021
Complainant Complainant
A…. B…… Acting
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