Traffic Accident Material-Material Compensation Lawsuit Petition
… TO THE JUDGE OF THE COURT OF FIRST INSTANCE;
THE PLAINTIFF :
TC IDENTITY NUMBER :
ADDRESS :
PROXY :
ADDRESS :
DEFENDANT :
ADDRESS :
SUBJECT : Due to Traffic Accident ….. TL. Material and …. TL. It consists of our request for moral compensation.
CASE VALUE :
EXPLANATIONS :
1-) …/ …/ … On …/ …/ … date, in the traffic accident with injury and death that occurred on … Street, the defendant … …, with his … plate vehicle, which we later learned that he was the owner, hit the … plate vehicle, which was owned by our client and which he was driving and managing on the day of the incident, from behind. In the traffic accident that occurred, our client was injured in the …, … and … regions, and his deceased wife … … died on the spot. (Annex-1)
2-) In the Traffic Accident Detection Report dated …/ …/ …/ … and numbered … kept by the traffic police team arriving at the scene of the accident, (ANNEX-2) it was determined that the accident occurred as a result of the car driven and managed by the defendant, who lost control due to excessive speed, hitting the car driven and managed by our client from the left rear, which was in normal course, and the vehicle driven by our client flipped over, and the defendant’s fault was determined as 100%.
3-) As a result of the traffic accident, our client had to be hospitalized for … days, paid … TL treatment costs for the period he was hospitalized (Annex-3) and started to take medication regularly since the day of the accident. (Annex-4) In addition, our client lost his wife of … years and started to take care of his … year-old child named … alone. Our client has started regular therapy in order to overcome the psychological breakdown he has experienced. (ANNEX-5) Even the relevant persons whose names are included in the witness list (ANNEX-6) attached to our petition regarding this situation will give explanations about the situation if deemed appropriate by your court.
5-) It has become necessary to file a lawsuit in order to compensate the material and moral damage suffered by our client to some extent.
LEGAL GROUNDS : 6098 S. Code Art. 49, 51, 53, 54, 56, 58; 6100 S. Code Art. 1, 2, 5, 6.
LEGAL EVIDENCE : Accident Report dated …/ …/ … and numbered …, hospital records, prescriptions, psychologist report, witness statements, expert examination.
CONCLUSION AND REQUEST : For the reasons explained above, we respectfully request on behalf of our client that …. TL financial compensation and … TL non-pecuniary compensation be taken from the defendant and given to the plaintiff, and that the trial expenses and attorney’s fee be charged to the other party. …/ …/ …
ANNEXES 1-) Hospital Records Indicating Death
2-) Accident Report dated …/ …/ … and numbered …
3-) Receipts Showing Treatment Expenses
4-) Prescriptions for Drug Use
5-) Psychologist Report
6-) Witness list showing the names and addresses of the witnesses and the subjects they will testify
7-) One approved power of attorney sample
Counsel for the Plaintiff
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