Petition for Compensation Due to Medical Malpractice

TO THE ON-DUTY CONSUMER COURT
OF ISTANBUL

PLAINTIFF: Name and Surname (Turkish Republic Identity Number: …) – Address
REPRESENTATIVE: Lawyer's Name and Surname – Address
DEFENDANT: … Inc. – Address
SUBJECT: Request for the defendant to pay … TL in material damages and … TL in moral damages.
VALUE OF CLAIM: … TL (Bodily damage)

EXPLANATIONS:

1. The plaintiff received an injection for treatment at the defendant company's hospital on …/…/… date. However, due to an error by hospital staff, the wrong medication was administered, resulting in severe bleeding in the plaintiff's left leg. Although the bleeding was noticed by hospital staff, albeit belatedly, they had difficulty controlling it. Consequently, the plaintiff's entire clothing became stained with blood and unusable. Due to the plaintiff's health condition, temporary medical reports were issued by the hospital administration.
2. The plaintiff is also a staff member at the defendant hospital. After the incident, she noticed that she was having difficulty walking and had a clearly observable limp. She began physical therapy at the hospital, but the treatment was ineffective; in fact, her condition worsened. When she informed the hospital management of her situation and requested to see another hospital or specialist, her request was rejected with the statement, "Everything necessary has been done here; you won't get a better result elsewhere." However, over time, serious problems such as thinning, shortening, loss of sensation, and balance problems began to develop in the leg that received the incorrect injection. This situation severely affected the plaintiff's daily life.
3. As a result of the thinning of the leg, the plaintiff no longer feels the same sensation as before, resulting in a loss of working capacity. Due to the loss of sensation, the plaintiff cannot stand for long periods, and the thinning causes pain in the leg. This undoubtedly negatively affects a person's normal daily life. For example, it is quite possible for the plaintiff to have difficulty climbing stairs or even bending down for simple tasks.Considering that the plaintiff could easily bend down, stand up, and climb stairs before the treatment, it is clear that he now has a leg that makes daily life difficult. Thisis unfortunately the case.
4. The serious health problems the plaintiff faced at a young age have profoundly affected her psychology. She is under intense stress due to the difficulties she encounters in her daily life and is currently receiving psychological treatment. Furthermore, the senior management of the defendant hospital is pressuring the plaintiff to work in difficult jobs, forcing her to resign. This process has further exacerbated the plaintiff's suffering, reaching the level of workplace mobbing.

EVIDENCE:

1. Defendant Hospital's patient file
2. Police investigation
3. Expert examination
4. Fault and disability report
5. Witness testimonies and other legal evidence

EVIDENCE : 1- Defendant Hospital file, 2- Police investigation, 3- Expert examination, 4- Fault and disability report, 5- Witness testimonies and other legal evidence. WITNESSES: 1- Name and Surname (Turkish Republic Identity Number: …) - Address 2- Name and Surname (Turkish Republic Identity Number: …) - Address CONCLUSION AND REQUEST: For the reasons briefly stated above, (rights to claim further damages reserved) , we request and demand that the defendant be ordered to pay … TL in material damages and … TL in moral damages, together with legal interest accruing from the date of the wrongful act , and that the court costs and attorney's fees be borne by the defendant . …/…/…

Plaintiff's
Attorney's Name and
Surname