Petition For Compensation Due To A Terrorist Act
To the Presidency of the Administrative Court;
PLAINTIFF : (TC No):
ADDRESS :
ATTORNEY :
ADDRESS :
DEFENDANT :
SUBJECT : This petition concerns our request for compensation for damages incurred due to a terrorist act under Law No. 5233.
OUR STATEMENTS
1-) Our client was injured on …/…/… while at a coffeehouse in … Village, … District, … Province, as a result of unknown individuals opening fire with automatic weapons at the coffeehouse.
2-) Our application seeking compensation for the damages incurred due to the injury, filed in accordance with Law No. 5233, was reviewed by the Damage Assessment Commission of the Governor’s Office of … Province, and as a result of this review, a draft settlement agreement proposing a payment of … TL to the client was presented. However, since our client did not accept this proposal, it became necessary to file this lawsuit via this complaint to seek the cancellation of the dispute record dated …/…/… and to claim compensation for the loss of earning capacity resulting from the incident, as well as … TL in medical expenses.
3-) Our client was hospitalized and received treatment due to the aforementioned incident and was unable to work for … days. Therefore, compensation for the … TL in material damages incurred is required.
4-) For the reasons explained above, it has become necessary for us to file this lawsuit within the statutory time limit to seek the annulment of the dispute record and compensation for the damages incurred.
LEGAL GROUNDS : Law No. 5233, Art. 4, 5, 6, 7, 9; Law No. 2577, Art. 15; Regulation on the Compensation of Damages Arising from Terrorism and the Fight Against Terrorism,
Art. 15, 16, 17
LEGAL EVIDENCE :
1-) Application letter to the Governor’s Office dated …/…/…
2-) Dispute record of the Governor’s Office dated …/…/…
3-) Hospital records
4-) All other relevant legal evidence.
CONCLUSION AND REQUEST : For the reasons explained above, we request the annulment of the decision of the Governor’s Office of … Province dated …/…/… and numbered …, as it pertains to our client, and the award of compensation in the amount of … TL in compensation, along with interest accruing from …/…/…, and that the litigation costs and attorney’s fees be ordered to be borne by the opposing party. …/…/…
ATTACHMENTS: 1-) Application letter to the Governor’s Office dated …/…/…
2-) Dispute report from the Governor’s Office dated …/…/…
3-) Hospital records
4-) Certified copy of the power of attorney.
Plaintiff’s Counsel
Attorney