Petition for Temporary and Permanent Disability Compensation

TO THE DUTY PRIMARY CIVIL COURT

ISTANBUL

PLAINTIFF: Name and Surname - (Turkish Republic Identity Number: …) - Address
REPRESENTATIVE: Lawyer's Name and Surname - Address
DEFENDANT: Name and Surname - Address
VALUE OF THE CLAIM: … TL (Unspecified Claim Case)
SUBJECT: While reserving our right to claim further amounts, we request that the amount of … TL, along with legal interest accruing from the date of this lawsuit, be collected.

EXPLANATIONS:

1. My client was injured and suffered serious health problems as a result of a traffic accident involving the defendant on [Date]. The accident was caused by a vehicle insured by [Insurance Company], which was reported. My client suffered temporary and permanent disability and financial losses as a result of the accident. The defendant had the right to claim compensation from the insurance company.

2. My client, during a period when he was struggling to cover his medical expenses and make ends meet, signed a "Assignment of Claims Agreement" with the defendant on [Date]. Through this agreement, the defendant agreed to transfer 25% of the compensation he would receive from the insurance company to my client.

3. Despite fulfilling all its obligations under the contract, the client repeatedly attempted to contact the defendant after the defendant failed to pay the compensation received from the insurance company. However, the defendant did not respond to the client's calls and did not pay the debt.

4. My client learned that the defendant received the compensation but did not pay him/her. This situation has caused my client harm and forced him/her to resort to legal action.

EVIDENCE:

1. Assignment of Receivables Agreement dated [Date]
2. The damage file of the reported [Insurance Company] regarding the accident subject to assignment
3. File information for any lawsuit filed against the reported [Insurance Company]
4. Expert Examination

LEGAL GROUNDS: Law of Obligations and related legislation

CONCLUSION AND REQUEST: For the reasons explained above, we request that the defendant be ordered to pay our client 25% of the compensation it received from the notified [Insurance Company]. The amount requested may be increased or decreased depending on the final amount to be determined as a result of the expert examination. For now, we respectfully request and demand that the defendant be ordered to pay … TL together with legal interest accruing from the date of the lawsuit, and that the court costs and attorney's fees be borne by the defendant. [Date]

Plaintiff's
Attorney's Name and
Surname