Complaint Petition Regarding Threats and Insults

TO THE REPUBLIC PROSECUTOR'S OFFICE

ISTANBUL

COMPLAINANTS:1- [Name and Surname] (Turkish Republic Identity Number: …)-[Address]

2- [Name and Surname] (Turkish Republic Identity Number: …)-[Address]

ATTORNEY: [Attorney's Name and Surname] - [Address]

COMPLAINED AGAINST:[Name and Surname]-[Address]

CRIME: Threat and Insult

DATE OF CRIME: [Date]

EXPLANATIONS:

1. The person complained about, [Name and Surname], called the phone number [Phone Number] belonging to our client, [Name and Surname], at [Time] on [Date] and insulted and threatened our clients during this phone call.
2. As can be seen from the audio recordings attached to our petition (APPENDIX 1: Audio recordings containing the conversation between our client [Name and Surname] and the person complained against), the person complained against, during a phone call with our client [Name and Surname], explicitly threatened and insulted our client and his/her spouse using expressions such as [expressed threats and insults]. The malicious intent and malice of the person who went so far as to imply that our client's husband was having an affair with our client's sister's daughter is evident. Despite all this, our client [Name and Surname] tried to remain calm, repeatedly telling the person not to speak like that, but the person continued in this manner. Even when our client mentioned that his/her grandchild was present, the person continued to make threats and insults.
3. Article 106 of the Turkish Penal Code, which regulates the crime of Threat, states: “(1) A person who threatens another person by stating that he will carry out an attack on his life, bodily integrity, or sexual integrity, or that of a close relative, shall be punished with imprisonment from six months to two years. If the threat is made by stating that he will cause great harm to his property or inflict other harm, upon the complaint of the victim, imprisonment of up to six months or a judicial fine shall be imposed.” Similarly, Article 125 of the same law, which regulates the crime of Insult, states: “(1) A person who attributes a concrete act or fact to another person that is capable of harming his honor, dignity, and reputation, or who attacks the honor, dignity, and reputation of another person by insulting him, shall be punished with imprisonment from three months to two years or a judicial fine. For an insult committed in the absence of the victim to be punishable, the act must be committed in the presence of at least three people.” (2) If the act is committed through an audio, written or visual message addressed to the victim, the penalty specified in the above paragraph shall be imposed.” In this context, as can be clearly understood from the conversation content given above, the actions of the person complained against constitute a crime within the scope of the Turkish Penal Code.
4. On the date the phone call took place, our clients were located within the borders of [Province Name] province, and since the residence of the clients who were harmed by the crime is also in [Province Name] province, it has become necessary for us to apply to your office as the competent prosecutor's office. For the reasons explained above, we are filing a complaint against the person named [Name and Surname] who harassed, threatened, and insulted our clients by phone, and we are submitting this petition to your office requesting that a public prosecution be initiated against this person for their actions which constitute a crime under the Turkish Penal Code.

EVIDENCE: Audio recordings, mobile phone records, and all other legally binding evidence related to the conversation between the client [Name and Surname] and the accused.

LEGAL GROUNDS: Turkish Penal Code and other relevant legislation.

CONCLUSION AND REQUEST
For the reasons stated and explained above, I respectfully request and demand that a public prosecution be initiated against the suspect, who has disturbed the peace and psychological well-being of the complainant clients with threats, insults, and abuse, and that he be punished in accordance with the relevant articles of the Turkish Penal Code.

Complainant's Representative

Lawyer's First and Last Name

Signature