-EXAMPLE PETITION-
CHAIRMAN OF THE INSURANCE ARBITRATION COMMISSION
APPLY
FOUND :A….. B….. (T.C.:…………)
address
attorney :
address
AGAINST
SUBMITTED AN APPLICATION
INSURANCE COMPANY: X INSURANCE A.Sh.
SUBJECT OF APPLICATION:../../…. For the time being, our claim for compensation for property damage of TL 000.00 suffered by the client due to a traffic accident that occurred on his date is about.
INSTRUCTIONS
The applicant client A….. B….., 06… Plate No…. October 1) The vehicle (a photocopy of the license is presented in the October of the petition)../../…. The insured property of the respondent insurance company C…. while moving towards Ostim from the direction of Batıkent in its history.. E….plate number 06 …, which belongs to ‘… Modelling …. Brand tool, ……………………. He was involved in a traffic accident with property damage at the intersection.
C….. E….‘s conduct in the vehicle, the location of the accident in violation of the rules and the speed limit of the vehicle speed by multiplying stand in the conduct of the client, the client was caused to crash into the vehicle in front and thus a pileup occurred.
Dec October 2), a Record of the Determination of a Traffic Accident with material damage between the parties was kept as a result of the incident. According to the defect report (tramer) issued in accordance with this minutes, C….. E….the vehicle with the number plate 06 … belonging to the is fully defective. C….. E…. In violation of Articles 52/1-a and b of the Road Traffic Code No. 2918, it caused the accident in question. As is fixed by the minutes, C….. E…. it is the main one that is defective in the incident, and the client has no defects in this accident.
Due to this accident, there are major damages to the vehicle Number 06 … License plate belonging to our client. The vehicle has suffered a significant depreciation. Your client from becoming unusable tool …….. Ostim Yenimahalle is located at the address of Ankara …. October 2017 – October 2017 – The car was in service for a long time and has been repaired here (invoices and documents are attached Annex-4). Repair and repair of the vehicle, defendant X Insurance A.Sh. it has been covered by the.
The client was unable to use the vehicle during the time his vehicle was in service, which created difficulties in his work and personal life. In addition, there is a large depreciation of the vehicle. The damage suffered by the client is still increasing. As is fixed by the procedure, the law and the established case law of the Supreme Court, the defendant insurance company is obliged to pay the amount of depreciation incurred by the plaintiff client.
../../…. With the notice of warning (ANNEX-3) sent from the Notary Public of Ankara dated October 3, the Insurance Company X has been requested to cover the damages suffered by the client. However, the respondent’s insurance company left the application unanswered and did not pay either.
For the reasons described above, it has been necessary to make this application to determine the cost of damage suffered by the client.
LEGAL REASONS: KTK, TTK, TBK, HMK, Law on Advocacy and other relevant legislation No. 6047
EVIDENCE : A photocopy of the vehicle’s license and policy, photos of the vehicles involved in the incident and the client’s vehicle after the accident, …/…/Dated 2021 ….. Accident Sequence Number is the Record of the Determination of the Traffic Accident Caused by Material Damage, ../../…. Dated Ankara … All delail notices, Auto Service invoices and documents, witnesses, expert witnesses, discovery and other sent from the Notary’s Office
CONCLUSION AND CLAIM: For all the reasons described above, we reserve the right to file a lawsuit and claim for an excess;
1-Defendant X Insurance A with interest on the loss of value in the amount of TL 000.00 for the time being, which occurred in the vehicle belonging to the client.Sh. collection from,
2- We offer and request that it be decided that the costs of the trial and the power of attorney be left on the counterparty. 26/11/2021
The Applicant’s Client
A…. B…… The Attorney
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