Request For Determination Of Optional Insurance
……. COURT
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
SUBJECT : Request for Determination of Voluntary Insurance.
EXPLANATIONS
1-) My client … is registered with the S.S.K. with the insurance registration number ….. My client has paid the premiums from …/…/… from the Optional Insurance branch of the … Insurance Directorate.
3-) The defendant institution initially accepted my client’s request to become an Optional Insured, collected all premium payments during the period between …/…/… – …/…/…/… and did not give any notice that the premiums paid were invalid.
4-) … Insurance Directorate collected the premiums that were not paid retrospectively with the receipt dated …/…/… dated …/…/… and numbered … with a printed “Optional Insurance Premium Collection Receipt” together with the delay increase. For these reasons, it has become compulsory for us to file a lawsuit for the determination of the voluntary insurance of my client, whose retirement request was not accepted.
LEGAL GROUNDS : Article 85 of 506 S. Law and related legislation.
LEGAL EVIDENCE : S.S.K. records, receipts, expert examination, witness statements and
other evidence
CONCLUSION AND REQUEST
For the reasons explained above, I respectfully request your Honorable Court to determine that the premiums paid as of …/…/…/… are Voluntary Insurance Premiums and that my client is a Voluntary Insured as of …/…/…/…, and that the costs of the proceedings be charged to the defendant. …/…/…
Counsel for the Plaintiff
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