27 Mar Example of a Petition for Damages Mental Anguish Due To a Traffic Accident
… TO THE JUDGE OF THE COURT OF FIRST INSTANCE;
PLAINTIFF :
TC IDENTIFICATION NUMBER :
ADDRESS :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
LITIGATION VALUE : ……….. TL
(In cases related to property rights)
Subject: it consists of asking for moral compensation due to a traffic accident.
INSTRUCTIONS :
1 -) … / … / … on the date of the traffic accident with injuries that occurred on the street, the defendant was hit from behind by a vehicle with a license plate that was in the dispatch and administration and we later learned that it was maliki, and our client was maliki and was in the dispatch and administration on the day of the incident. In the car accident, our client was injured in the area, with a broken spine and stable marks on various parts of his body. Children who were also in the same vehicle as our client at the time of the accident were also injured. This situation is also fixed by the hospital reports (Annex-1) dated…………………
2-) held at the scene of the accident …/ …/ … traffic accident date and numbered in the 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, it was determined that occurred as a result of, and our client could not be attributed to any defect.
3 -) Our client, as a result of the traffic accident, was stuck in the vehicle and … had to lie in the Hospital (Annex-3) for the day. In addition, despite the treatment of our client’s broken spine, it was not possible to prevent our client from being partially crippled. Due to the discomfort caused by the state of disability and constant marks on the body, as well as the psychological trauma caused by seeing the injuries of his own children in the same accident, our client was extremely upset and his mental health (Annex-4) deteriorated.
4 -) within the framework of the provisions of the Code of Obligations No. 6098 on tort, our client has the right to compensation.
5 -) in order to cover some of the moral damage experienced by our client, it was necessary to open this indefinite claim and determination case.
Legal reasons: 6098 P. K. m. 49, 50, 51, 52, 53, 54, 56, 75, 6100 S. K. m. 2, 3, 107
Legal evidence : … / … / … and … / … / … dated……. Hospital reports, … / … / … date and … numbered traffic accident detection report, … / … / … dated…. Hospital patient discharge document, psychiatric examination report of the hospital …/…/…
Conclusion and request : for the reasons described above, the value of our client’s full of moral damage as a result of the inquest and the minimum possible time, allowing it to be precisely determined to be at increased[1] ……..TL non-pecuniary damages for the tort occurred on the date …/…/… from the defendant with legal interest from the date of collection and litigation costs and attorneys ‘ fees yukletilm being decided to the opposite side of it, we respectfully request on behalf of our client. …/ …/ …
Adds: 1 – … / … / … and … / … / … dated……..,
2 – … / … / … date and … numbered traffic accident detection protocol,
3 – … / … / … dated …. Hospital Patient Discharge Document,
4 -…… psychiatric examination report of the hospital …/…/…
5-one sample of approved power of attorney.
Acting Plaintiff
Lawyer
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