Petition for Monetary Damages within the Scope of Motor Vehicle Operator's Liability

TO THE ISTANBUL DUTY PRIMARY CIVIL COURT

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

ATTORNEY: Lawyer's Name, Surname, and Address

DEFENDANT: Name and Surname - Address

SUBJECT: Monetary compensation

VALUE OF THE CLAIM: … TL

EXPLANATIONS:

1- My client opened his shop on …/…/… for business purposes. A car with license plate number …, owned and operated by the defendant …, entered the shop, severely injuring my client, who was then rushed to the hospital. The police report prepared at the scene determined that the speed limit on the road leading to the shop was exceeded, and that the driver engaged in activities that endangered safe traffic (slalom and drifting), thus violating traffic rules. CCTV footage from outside the shop also confirmed this. The police determined that the defendant was primarily at fault.

2- As a result of the accident, my client suffered fractures to his back and leg, and while he had just recently incurred expenses for the shop, the vehicle crashing into the shop caused significant financial losses. He also has to pay for his hospital treatment. My client had only recently opened the business and was the sole employee, therefore he suffered a major economic loss and is experiencing financial hardship due to being unable to go to work.

3- My client's total current losses, including medical expenses and damage to the shop, amount to approximately ... Turkish Lira. This lawsuit has been filed to seek compensation for the material damages suffered by my client from the defendant, who negligently caused the traffic accident.According to Article 85 of the Highway Traffic Law No. 2918, if the operation of a motor vehicle causes death or injury to a person or damage to property, the person or persons considered to be the operator shall be held liable for this damage.

EVIDENCE: 1- Accident report, 2- Hospital reports and invoices for payments I made to the hospital, 3- Police reports, 5- CCTV footage, 6- Expert opinion, 7- Witness testimony, 8- Interrogation report, 9- On-site investigation, 10- Oath and other evidence

LEGAL GROUNDS: Article 85 of the Highway Traffic Law and other relevant legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand, as the plaintiff's attorney, that the case be accepted, that the defendant be ordered to pay the plaintiff ... Turkish Lira in material compensation, together with legal interest accruing from the date of the incident, reserving our rights regarding any further claims, and that the court costs and attorney's fees be borne by the defendant.

…/…/…

Plaintiff's
Attorney's Name and
Surname

(Prepared by: Student Intern Simay Şirin)