Petition for Recovery of Lost Profits During Vehicle Repair Period Following a Traffic Accident

TO THE DUTY PRIMARY CIVIL COURT
OF ANKARA

PLAINTIFF: Name and Surname – (Turkish Republic Identity Number: …) – Address
REPRESENTATIVE: Lawyer's Name and Surname – Address
DEFENDANT: Name and Surname – Address

SUBJECT: This is a claim for the recovery of … TL plus accrued interest from the defendant, reserving our rights to claim further amounts, for the loss of services and earnings suffered by our client company during the repair period of its vehicle following a traffic accident on …/…/….

EXPLANATIONS:

1. The client company owns the minibus with license plate number … and is managed by … and its vehicle was damaged as a result of a traffic accident that occurred on …/…/… with the defendant's bus with license plate number … on … street. As a result of this accident, according to the traffic accident report, the defendant's driver was deemed primarily at fault pursuant to Article 52/6 of the Highway Traffic Law No. 2918, while the client's driver was found blameless.
2. The client's vehicle was in repair for 15 days following the accident, during which time the client was deprived of the services provided by the vehicle. The client company is a leading and expert firm in Türkiye, offering sales and authorized service in Ankara and throughout the country. The client company incurred additional expenses to ensure that services were not interrupted while the vehicle was in repair.
3. This lawsuit has become necessary to compensate for the loss of earnings suffered by the client as a result of the accident and to obtain redress for the damages incurred. A sum of … TL is currently being requested to cover the client's financial losses.

LEGAL GROUNDS: Highway Traffic Law, Turkish Code of Obligations, and other relevant legislation.

EVIDENCE:

1. Traffic accident report
2. Witness statements
3. Expert examination 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 stated above, and reserving our rights to claim further amounts, I respectfully request and demand on behalf of my client that the defendant be ordered to pay the amount of … TL plus legal interest accruing from the date of the accident, and that the court costs and attorney's fees be borne by the defendant.

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