2.1 CLAIM FOR INSURANCE COMPENSATION OF A STOLEN VEHICLE

TO THE ISTANBUL CIVIL COURT OF FIRST INSTANCE

PLAINTIFF: DD (Turkish National Identity Number: 11111111111)
Kartal neighborhood, 15th Street, No: 11/11, Bahçelievler/Istanbul

REPRESENTATIVE: Attorney Sabahat YILMAZ - UETS

DEFENDANT: Y. Insurance Inc.

SUBJECT OF THE LAWSUIT: The lawsuit concerns the claim for payment of the vehicle's value, plus legal interest, by the defendant company due to the theft of the vehicle insured under policy number 222222222

EXPLANATIONS

1) THE VEHICLE WAS STOLEN BY UNKNOWN PERSONS. The vehicle with license plate number 34 XXX 123, belonging to my client and covered by comprehensive insurance policy number 222222222 with the defendant insurance company, was parked by my client on Ç. Street in KK. Neighborhood on 01/01/2026 at approximately 22:30. When my client went to where he had parked the vehicle on 02/01/2026 at approximately 09:00, he found that the vehicle was gone and, after inquiring with the surrounding area, understood that his vehicle had been stolen by unknown persons . As can be seen from the Vehicle Theft Report attached to our petition, my client immediately reported the incident to the police station and filed a complaint against the individuals who stole his vehicle.

2) THE DEFENDANT INSURANCE COMPANY REFUSED TO COMPENSATE FOR THE DAMAGES. The plaintiff, whose vehicle was insured under a comprehensive insurance policy, applied to the defendant insurance company for compensation after his vehicle was stolen by unidentified individuals . In its response, the defendant insurance company unjustly and baselessly refused to compensate the plaintiff, claiming that the theft did not occur at the specified location, manner, and date . The refusal letter was also sent to X. Insurance Brokerage Services Ltd. Co., the agency that issued the comprehensive insurance policy for the vehicle . In conclusion, the vehicle was insured under a comprehensive insurance policy issued by the plaintiff with the insurance company. After the theft, the plaintiff reported the incident to the insurance company , submitted the necessary documents, but the insurance company did not make the payment and sent an unjust refusal letter. As can be seen, due to the theft of the vehicle under the comprehensive insurance policy, the defendant insurance company, which is obligated to compensate my client for the damage, unjustly and without basis rejected our claim, thus necessitating the filing of this lawsuit. Because the insurance company failed to fulfill its payment obligation, the plaintiff requests a court decision ordering the collection of the insurance amount (market value) along with default interest.

LEGAL GROUNDS
• Insurance contract, Turkish Commercial Code, Turkish Code of Civil Procedure, Turkish Code of Obligations, and all relevant legislation.

EVIDENCE • Comprehensive car insurance policy number 222222222, • Premium payment receipts, • Car theft report, • Vehicle registration certificate , • Police/gendarmerie report regarding the theft, • Public Prosecutor's Office investigation file , • Notifications and applications submitted to the insurance company, • Letter/rejection response from the insurance company stating that they did not make the payment, • Expert report regarding the market value of the vehicle, • Damage/expert report prepared by the insurance company, • HTS, MOBESE, camera recordings (to be requested if necessary) , • Witness statements , • Expert examination , • Oath , • On-site inspection , • All kinds of legal evidence

CONCLUSION AND REQUEST For the reasons explained above, and reserving our rights regarding any further claims, we request and demand: 1. The recovery of the vehicle's value, along with legal interest, due to the theft of the vehicle insured under policy number 222222222. 2. That the court costs and attorney fees be borne by the defendant .

Plaintiff's Attorney
: SABAHAT YILMAZ