Petition for Recovery of Lost Profits During the Vehicle Repair Process

TO THE DUTY PRIMARY CIVIL COURT
OF ISTANBUL

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

ATTORNEY: Lawyer's Name, Surname, and Address

DEFENDANT: Name and Surname - Address

SUBJECT: This is a statement and claim regarding lost profits and accrued interest from the date of the accident that occurred on …/…/…, reserving our rights to claim further amounts.

EXPLANATIONS:

• On …/…/…., the vehicle with license plate number ….., under the management of the client-owner, was struck by the vehicle with license plate number …… at approximately … o'clock, due to exceeding the speed limit. The owner of the vehicle with license plate number ….., who was driving contrary to the circumstances, was found at fault according to the accident report prepared in accordance with Article 52/6 of the Turkish Road Traffic Law No. 2918. It has been determined in writing that the owner of the vehicle with license plate number ….. is primarily at fault.
• 2- According to the traffic accident report prepared after the accident, the driver of the defendant's bus with license plate number …, was deemed primarily at fault according to Article 52/6 of the Traffic Law No. 2918. The driver of the client's vehicle was deemed blameless. Therefore, the driver of the vehicle with license plate number … is 8/8 at fault.
• The vehicle belonging to the client company was under repair for 15 days, and the damage was covered by its own insurance. However, considering that the client's profession is ……, the service was interrupted/stopped for …. days. The client (company) is a professional (or firm) providing …… services, specializing in …… and possessing a rare level of success in Türkiye. Given the loss of profit and earnings suffered by the client (company) in this situation, it has become essential for us to file this claim for reimbursement in the interest of fairness.

LEGAL GROUNDS: Traffic Law 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 briefly explained above, reserving our rights to claim further amounts, I respectfully request and demand that the defendant be ordered to pay …TL plus 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's Name and
Surname