08 Feb A PETITION FOR MATERIAL AND NON-PECUNIARY DAMAGES FOR A TRAFFIC ACCIDENT
TO THE COURT OF FIRST INSTANCE;
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
address :
DEFENDANT :
ADDRESS :
SUBJECT : Due to a Traffic Accident ….. TL. Material and …. TL. It Consists in Our Request for Moral Compensation.
CASE VALUE :
INSTRUCTIONS :
1-) … / … / … in the history of a traumatic and fatal traffic accident that occurred on … … Street, the defendant hit a vehicle with a license plate that we later learned was maliki and a vehicle with a license plate that our client was Maliki and was in the dispatch and administration on the day of the incident from behind. In the traffic accident that occurred, our client was injured in the area of his and his deceased wife died at the scene. (APPENDIX-1)
2-) is maintained by the traffic police team from the scene of the accident …/ …/ … traffic accident date and numbered in minutes (Appendix 2), the accident, the car lost control due to excessive speed and in the conduct of the defendant located in the normal course of our client referral and administration the left of the vehicle in a rear-end collision, as a result of our client’s use of the tool for the somersault determined that occurred as a result of the defendant of the defect as 100% was determined.
3-) As a result of the traffic accident that occurred, our client had to stay in the hospital for several days, paid TL treatment costs for the period he was hospitalized (ANNEX-3) and started taking medication regularly since the day of the accident. (ANNEX-4) In addition, our client has lost his wife of one year and has started to take care of his one-year-old child by himself. Our client has started regular therapy in order to overcome the psychological depression he is experiencing. (OCTOBER October 5) Even the relevant persons whose names are included in the witness list (annex 6) presented in the annex to our petition regarding this situation will also give explanations about the situation if deemed appropriate by your court.
5-) In order to cover the material and moral damage suffered by our client to some extent, it has been necessary to file a lawsuit.
LEGAL REASONS : 6098 P. K. m. 49, 51, 53, 54, 56, 58; 6100 P. K. m. 1, 2, 5, 6.
LEGAL EVIDENCE: …/ …/ … date and … numbered Accident Detection Minutes, hospital records, prescriptions, psychologist’s report, witness statements, expert review.
CONCLUSION AND REQUEST: For the reasons described above, we respectfully request on behalf of our client that it be decided that TL material and TL moral compensation will be taken from the defendant and given to the plaintiff, and that the trial expenses and the attorney’s fee will be charged to the other party. …/ …/ …
APPENDICES: 1-) Hospital Records that Show Death october
2-) …/ … / … date and … numbered Accident Detection Minutes
3-) Receipts that Indicate the Costs of Treatment
4-) Prescriptions for the Use of Medicines
5-) Psychologist’s Report
6-) Shows the names and addresses of the witnesses and the topics they will testify to witness list
7-) An example of a certified power of attorney
Plaintiff’s Attorney
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