……. TO THE HONOURABLE JUDGE
REQUESTING DETERMINATION :…….
REPRESENTATIVE :…….
AGAINST PARTY :…….
SUBJECT : Damage Determination
EXPLANATIONS : 1-The vehicle with the licence plate number ……. driven and managed by our client ……. on ……. …. While travelling normally towards ……. within the borders of the town of ……., a traffic accident with material damage occurred as a result of the vehicle with the number plate ……. owned by the other party ……. and driven and managed by ……. entering the road uncontrollably from the left side according to the direction of the road at around ……. on ……..
2-While our client’s vehicle was travelling normally on ……. with the vehicle with ……. plate number ……. under the direction and management of the other party driver ……., the driver caused the accident with 100% fault by committing the defect of “changing direction and making wrong manoeuvre” and violating Article 47/1d of the law numbered 2918. Our client has no fault in the incident. Our client’s vehicle is located in the industry at the address to be notified later.
3- Due to this accident, a large amount of damage has occurred to my client’s vehicle.
Since we will file a lawsuit against the other party ;
The amount of damaged parts in our vehicle,
Repair and labour costs of damaged parts,
Loss of value,
Depreciation loss,
How many days it will take to restore the vehicle,
How much the absence expense will be
It has become obligatory to request its determination by an expert.
LEGAL GROUNDS : Code of Civil Procedure, Code of Obligations, TCC and Related Legislation
EVIDENCE : Traffic Accident Report,
CONCLUSION OF THE REQUEST : For the reasons stated above, we request that the above-mentioned issues be decided to be determined by the expert expert to be selected by your Court, that the costs of the determination be charged to the other party, and that the counterparty attorney fee be decided on our behalf as a lawyer in accordance with the 164/last paragraph of the Law No. 1136 on Attorneyship Law amended by Law No. 4667.
REPRESENTATIVE OF THE REQUESTING DETERMINATION
……..
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