Material Damage Traffic Accident Report
Sample Petition for Receivable Lawsuit arising from Material Damage Traffic Accident
… JUDGESHIP OF THE COURT OF FIRST INSTANCE
THE PLAINTIFF :
TC ID NUMBER :
ADDRESS :
PROXY :
ADDRESS :
DEFENDANT :
ADDRESS :
SUBJECT : …./…./…./…. Together with the legal interest to be processed as of the date of the event of our receivable arising from the material damage traffic accident that occurred on the date; It is the request of our request to collect jointly and severally from the defendants and to put an injunction on the traffic records in order to prevent the transfer and assignment of the vehicle that caused the damage to third parties.
CASE VALUE :
EXPLANATIONS :
1-) The incident occurred on …./…./…. on ….. province, …. district, ……………. address, ……….. license plate and the vehicle belonging to our client parked at …………….; In the traffic accident that occurred when the ……. license plate vehicle driven and managed by …. …., whose owner is …. ….., hit from behind, the vehicle belonging to our client suffered material damage.
2-) Due to the traffic accident in question, the total damage of ………….. TL damage to our client’s vehicle due to the traffic accident in question is also understood from the service report where the vehicle subject to the lawsuit was taken after the date of the incident and the expert report dated …/…/…. of …… Sigorta A.Ş., which carries the compulsory financial liability insurance of the vehicle with the policy number ………
3-) However, on the day of the incident, immediately after the accident, …./…./…./…. Although the accident report dated ……/…../….. was submitted to the insurance company on ……/…../….. and the amount of damage in question was requested, no payment has been made to us until today.
4-) As of the day of the accident, the value of the vehicle subject to the lawsuit, which had a fair market value of …… TL as of the day of the accident, decreased to ……. TL after the accident. Since no payment has been made despite the submission of the accident report to the relevant insurance company, it has become necessary to file the present lawsuit for the compensation of the loss of value and other issues suffered by our client.
LEGAL GROUNDS : 2918 S. K. Art. 92, 99, Highway Traffic Regulation Art. 157,
158, Art. A.1, B.4 of the General Terms and Conditions of Compulsory Financial Liability Insurance for Motor Vehicles, Art. 2, 6, 119, 266, 288, Art. 1409, 1472 of the Law No. 6102.
LEGAL EVIDENCE : Accident report, photographs of the vehicle, insurance company expertise report, service invoice, insurance policy, discovery, witness, expert examination.
CONCLUSION AND REQUEST : For the reasons we have tried to present and explain above; In order to prevent the transfer and assignment of the vehicle that caused the accident to third parties, we request, on behalf of our client, that an injunction be placed on the traffic record, that the loss of value of ……..TL that occurred in our client’s vehicle be jointly and severally collected from the defendants with legal interest from the date of the incident …/…/…., and that the court costs and attorney’s fees be imposed on the other party. …/…/…
ANNEXES : 1. …/…/… dated accident report,
…/…/… dated expertise report,
…/…/…/… dated service report and service invoice,
Insurance Policy
Photographs of the damage to our client’s vehicle,
The names and addresses of the witnesses and the subjects they will testify about
a list of witnesses,
One approved power of attorney sample.
Plaintiff Attorney
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