Sample Petition Regarding Vehicle Damage and Decrease in Value

…TO THE PRIMARY CIVIL COURT

PLAINTIFF: Name and Surname – (Turkish Republic Identity Number: …) Address: [Plaintiff's current address suitable for service of process]

ATTORNEY: Attorney's Name and Surname Address: [Attorney's current address suitable for service of process] (If there is no attorney, this section is omitted)

DEFENDANT: Name and Surname – (Turkish Republic Identity Number: …) / [or Company Name – Tax Identification Number: …] Address: [Defendant's known address]

SUBJECT: [A brief and clear summary of the subject of the lawsuit, e.g., a claim for damages arising from a tort, receivables due to breach of contract, etc.]

VALUE OF THE CLAIM: … TL (Value for Fee Calculation) (If the value of the claim is uncertain: … TL for now, reserving our rights regarding any excess amount)

EXPLANATIONS

1- [This section describes the beginning and development of the event in question in chronological order. The legal relationship between the parties (e.g., contract, neighborhood, tort, etc.) is defined.]

2- [The factual circumstances forming the basis of the dispute are detailed. It is specified which action or inaction of the defendant caused the damage to the plaintiff and which clause of the contract was breached.]

3- [The damages (material and/or moral) suffered by the plaintiff in relation to the incident in question are explained. The items and amounts of these damages are specified.]

4- [Legal actions taken before filing a lawsuit, such as notices of default and mediation processes, and their outcomes, are described in this section.]

5- [In light of all that has been explained, it is stated that the reasons giving rise to the defendant's liability and the necessity of filing this lawsuit have arisen.]

LEGAL GROUNDS: Code of Civil Procedure, Turkish Code of Obligations, Turkish Commercial Code, and other relevant legislation.

EVIDENCE: [All evidence that can be used to prove the claim in question is listed here. For example: contract dated …, invoices, bank statements, witness list (names and addresses will be provided separately), expert examination, on-site inspection, sworn testimony, message and email records, warning letter, and all other legal evidence.]

CONCLUSION AND REQUEST: For the reasons stated and explained above, and in accordance with matters to be considered ex officio (on its own initiative), and reserving our rights regarding any further claims;

1- [The main claim is written here. Example: ... TL in material compensation, to be collected from the defendant together with legal interest accruing from ... date (or the date of the lawsuit),]

2- [If any, other claims are written down. Example: … TL moral damages…]

3- The court costs and attorney's fees shall be borne by the defendant

I respectfully request and demand that a decision be made.

…/…/… (History)

Plaintiff's (or Representative's) Name and Surname (Signature)

ATTACHMENTS: 1- [Documents referenced in the evidence list (Contract, Invoice, etc.)]

2- [If any] Final Mediation Report

3- [If applicable] Copy of Power of Attorney 4- Photocopy of Identity Card