……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT :
The claim for the collection of ………………….-TL … / … / …. together with bank rediscount interest, costs and attorney fee from the date of payment.
FACTS :
1- The premises insured on behalf of ………………………………………………………………………………………… with the insurance policy numbered ……………… before our company ……………… was damaged as a result of a fire at the defendant’s workplace on … / … / …..
2-TL ………………………-TL damage compensation, which was determined as a result of the expertise made at the insured location, was paid to our insured.
3-With the payment of the damage, according to the terms of the contract and the provision of Article 1301 of the Commercial Code, our company has become a successor in place of the insured and all existing rights of the insured against those who caused the damage have been transferred to our company.
4-According to the minutes and expertise report issued in relation to the incident, it has been determined that the defendant is responsible for the damage incurred. Since the defendant is liable to our insured and therefore to our Company, which stands in its place, it has become necessary to file this lawsuit.
LEGAL GROUNDS: Code of Civil Procedure, Code of Civil Procedure, Turkish Commercial Code, Traffic Law and related legislation provisions.
EVIDENCE : Policy, determination report, expert examination and all kinds of legal evidence.
RESPONSE PERIOD : 10 days
CONCLUSION AND REQUEST :
As stated above, we request and demand that the parties be notified and that as a result of our lawsuit, ……………………………-TL … / … / …. be decided to be collected from the defendant together with bank rediscount interest, costs and attorney fee from the date of payment.
Plaintiff Attorney
…….
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