Petition for a Financial Damages Lawsuit We Filed Against Our Own Insurance Company

TO THE ON-DUTY CONSUMER COURT
OF ANKARA

PLAINTIFF:
Name and Surname – (Turkish Republic Identity Number: …) – Address

ATTORNEY:
Lawyer's Name and Surname – Address

OPPOSING PARTY:
… Insurance Inc. – Address

SUBJECT OF THE LAWSUIT:
Indefinite lawsuit (claim for compensation for a traffic accident, for now…)

EXPLANATIONS:
1- On …/…/…, while my client was driving his vehicle with license plate number …, a vehicle coming from the opposite direction, which had the right of way, passed through the red traffic light and collided with my client's vehicle. As a result of this collision, my client's vehicle was severely damaged. The accident was caused by the negligent behavior of the driver of the vehicle with license plate number …. The material damage to my client's vehicle and the degree of fault in the accident have been determined, and my client has been found to be %… at fault.

2- Following the incident, our client applied to … Insurance Inc., but the insurance company has not responded. Despite the existence of an insurance policy, the necessary payment has not been made to our client due to the degree of fault.

3- Currently, an expert examination is required to determine the exact amount of actual damages. However, for now, ... compensation is being requested in this lawsuit. Our rights regarding further claims are reserved, and the amount of compensation will be determined through further examinations in the future.

EVIDENCE:
1- Accident report,
2- Insurance policy for the vehicle with license plate number …,
3- Repair and maintenance invoices issued by the authorized service center,
4- Photographs and other documents related to the accident,
5- Application documents submitted to the insurance company,
6- Other legal evidence.

LEGAL GROUNDS:
Turkish Civil Code, Code of Civil Procedure, Turkish Code of Obligations and related legislation.

CONCLUSION AND REQUEST:
For the reasons stated above, and reserving our rights regarding further claims, I respectfully request that the defendant be ordered to pay the material damages, together with commercial interest accruing from the date of their default, that an inspection date be set for the examination of the file, and that the court costs and attorney's fees be borne by the defendant.

…/…/…
Plaintiff's
Attorney Name and Surname
Signature

ATTACHMENTS:
1- Copy of power of attorney,
2- Application documents submitted to the insurance company,
3- Photographs of the vehicle, accident report and invoices,
4- Authorized service repair and maintenance documents,
5- "Receipt of Receipt" showing the delivery date from the postal service.