TO THE ISTANBUL PUBLIC PROSECUTOR'S OFFICE

Complainant (Plaintiff):
Name and Surname: EY (Turkish Republic Identity Number: …)
Address: …/Istanbul
Tel/Email: …

Representative:
Attorney YAĞMUR YUMLU
Address: …

Suspect(s):

1. YK TC: …) – The complainant's ex-boyfriend
2. The accompanying person, whose identity will be determined (male, approximately 30-35 years old, bearded; visible in the CCTV footage from the scene)

Crimes:

• Intentional injury (Turkish Penal Code Article 86)
• Insult (Turkish Penal Code Article 125)
• Threat (Turkish Penal Code Article 106)
• Deprivation of liberty (Turkish Penal Code Article 109)

Date and Time of Crime: October 24, 2025 – approximately 8:15 PM
Location: Istanbul/Şişli, … Neighborhood, … Street, No: … apartment entrance and landing

EXPLANATIONS:

1. The complainant, EY, encountered her former boyfriend, YK, in front of her apartment building on October 24, 2025, at approximately 8:10 PM while returning home from work . The suspect, unable to accept the termination of their relationship which had ended about three months prior, blocked her path, saying, " You can't escape me, I will humiliate you ."
2. As the complainant entered the apartment building and headed towards the elevator, the suspect grabbed her arm forcefully, pushed her against the wall in the building's landing , slapped her once in the face, and threatened her life, physical integrity, and relatives , saying, " I will kill you here, and I will not let your family see the light of day . " These words of YK constitute an unlawful threat of serious harm to the victim's life and physical integrity (Article 106/1). Due to the slap and the squeezing, the complainant sustained redness and swelling in her left wrist and tenderness in her right cheek .
3. The suspect's act of slapping and forcefully squeezing the victim's arm resulted in pain and impaired health. The injury documented in the report Article 86/2 .
4. The suspect used insulting language, including terms like " immoral" and "lacking in honor ," and prevented the complainant from accessing their apartment for 10-15 minutes by blocking the steel door on the landing. Blocking the entrance to the apartment building's landing and preventing the complainant from freely moving around and accessing their apartment for 15 minutes constitutes unlawful coercion ( Turkish Penal Code Article 109)
5. At that moment, a neighbor living in the apartment building opened the door and asked, "What's going on?" The suspect responded, "It's a family matter, don't interfere," and continued his insults. There are concrete acts and abusive language that are damaging to the victim's honor, dignity, and reputation. The fact that these words were uttered in a public apartment building and heard by neighbors also raises the possibility of a public offense (Article 125/4).
6. A second suspect, a man who arrived at the scene on a motorcycle and as a lookout , told the suspect Yasin, "Let's get this over with quickly." The suspects quickly left due to other neighbors approaching the scene, and that same night via WhatsApp saying, "Think about what will happen if you ignore me again."
7. The complainant went to Ş.M. Training and Research Hospital on the morning of October 25, 2025, and received a report indicating "injuries that can be treated with simple medical intervention ." Due to the psychological impact of the incident, she also sought treatment at the psychiatry outpatient clinic .

EVIDENCE:

1. Assault report dated 25.10.2025 (Ş.M. EAH)
2. Security camera footage from the scene (... Apartment entrance, ... Market exterior, ... Street CCTV)
3. WhatsApp conversations and threatening messages (screenshots from 24-25.10.2025)
4. Witness accounts:
   • CD (… Apt. Floor:3 No:7) – the neighbor who heard the incident and opened the door
   • BE (Security guard from the building across the street) – witnessed the argument in front of the door.
5. Building management entry and exit records (if any)
6. Base station/HTS records from the area (to confirm that the suspect was in the area at the time of the incident)
7. on the suspect's phone and iCloud/Drive accounts (search and copying under Article 134 of the Turkish Criminal Procedure Code).
8. Forensic examination and psychiatric evaluation reports, if necessary.

(All evidence will be submitted by us, and the decision to issue and summon evidence is at the discretion of your Prosecutor's Office.)

 REQUESTS RELATED TO INVESTIGATION PROCEDURES:

1. The suspect Yasin Kara's statement should be taken immediately , and the records of the phone and SIM card he used on the date of the incident, as well as those in messaging applications , should be examined in accordance with Article 134 of the Code of Criminal Procedure .
2. The CCTV and private security camera footage from the scene must be immediately secured and obtained (there is a risk of loss if there is a delay).
3. Identification of the unidentified person accompanying the suspect from camera footage; preparation of a physical identification report and a search for the suspect 's identity .
4. Based on information that the suspect possessed weapons, a search was conducted at his residence and vehicle, and weapons and ammunition were seized (CMK 116-119).
5. Urgent assessment of protective/preventive measures for the victim's safety (if necessary, restraining order, communication ban, prohibition from approaching the residence , precautionary measures under Law No. 6284 ) and confidentiality of the complainant's address information .

CONCLUSION and REQUEST:

For the reasons explained above, we respectfully request that a public prosecution be initiated against suspect YK and other suspects whose identities will be determined, pursuant to Articles 86, 106, 109 and 125 of the Turkish Penal Code , for the actions that took place in Istanbul/Şişli on October 24, 2025 ; that evidence be collected urgently; that necessary protective measures for the victim's safety be evaluated immediately; and that our request for participation (intervention) in accordance with Article 237 of the Code of Criminal Procedure be accepted during the prosecution phase, and that a decision be made to punish the suspects.

Date: 03/11/2025

Complainant (Plaintiff)
EY
Signature

Attorney
YAĞMUR YUMLU
Signature

Attachments:

1. Assault report dated 25.10.2025 (1 page)
2. WhatsApp screenshots (… number)
3. Power of attorney sample
4. Scene sketch and camera location plan (if available)
5. Witness list and contact information