……. TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT :……………………………………..-TL will start from … / … / …. payment date, …………………………-TL will start from … / … / …. payment date (Total ……………………….-TL Without prejudice to our claim rights regarding the excess) bank rediscount interest, costs, attorney’s fee.
EVENTS :
1-The theft incident occurred on … / … / …. at the workplace insured on behalf of …………………………………………. with the insurance policy numbered ……………… before our company.
2- One of the defendants………………………….. who committed the act, ………… ………….. caused our client to suffer damage by not properly caring and supervising the minor under his custody (……….. ……………..). Our insured ……………………………. against our company and the defendants ……………. A lawsuit was filed against our Company and the defendants with the number ……./…… E. of the Civil Court of First Instance and in relation to the concluded lawsuit, ………………………-TL was deposited to the ……. numbered file of ……. on 04.07.2002 and …………………-TL was paid to our insured on 21.07.2000, totalling ……………………..-TL.
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 the 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 of the incident and the Court Decision, it has been determined that the defendants are responsible for the incident. Since the defendants are liable to our insured and therefore to our Company, which stands in his 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 : The policy, ……………… The judgement of the Civil Court of First Instance numbered 2000/503 E., ……./……. K numbered judgement 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 defendants together with the bank rediscount interest, costs, attorney’s fee from the date of payment of 04.07.2002 of ………………………………………-TL and 21.07.2000 of ……………………………-L (without prejudice to our rights to demand more than …………………….-TL in total). …….
Plaintiff Attorney
…….
You can access our other article examples and petition examples by clicking here.