Petition for a Traffic Accident Resulting in Injury
TO THE PRIMARY COMMERCIAL COURT OF
ISTANBUL
PLAINTIFF:[Name Surname] (Turkish Republic Identity Number: …)-[Address]
ATTORNEY: Attorney [Name and Surname]-[Address]
DEFENDANT: [Insurance Company Name] Inc. - [Address]
SUBJECT OF THE CASE: Uncertainty Case Pursuant to Article 107 of the Code of Civil Procedure (Claiming for X TL Compensation Due to a Traffic Accident)
EXPLANATIONS
1. On ../../…., an accident occurred caused by the driver of the vehicle with license plate number … driven by … …, and my client suffered damages as a result of this accident.
2. My client was injured and suffered a loss of working capacity due to this accident, which occurred without any fault of his/her own. First and foremost, considering the economic damage that will result from the loss of working capacity and the permanent disability that will prevent him/her from performing his/her professional activities, a monetary compensation of X TL is requested, with the right to claim further amounts reserved, and an expert assessment is requested to determine the monetary compensation.
EVIDENCE
1. Insurance policy number ... for the vehicle with the registration number
3. SGK (Social Security Institution) records
3. Traffic Accident Report
4. Expert examination, on-site inspection, witness testimony…
LEGAL GROUNDS:
Code of Civil Procedure, Civil Code, Code of Obligations, Commercial Code and other relevant legislation.
CONCLUSION REQUEST
For the reasons stated above, reserving the right to claim further damages, we respectfully request and demand that the lawsuit be accepted
and a decision be made regarding the claim for XTL in pecuniary damages, and that the court costs and
attorney's fees be borne by the defendant.
…/…/20…
[Plaintiffs' Name and Surname]
[Attorney's Name and Surname]
[Signature]