-EXAMPLE PETITION-
ANKARA SENTINEL MAGISTRATE’S COURT ( )
PLAINTIFF/
REQUESTING DETECTION/
REQUESTING :A….. B….. (T.C.:…………)
address
attorney :
address
DEFENDANT/
THE OTHER SIDE :C….. E…. (T.C.:………..)
address
SUBJECT OF REQUEST :../../…. After the traffic accident that occurred on the date of; 06 … License plate number owned by the client …. Modelling …. The trademark is about our requests to determine the damage caused to the vehicle.
INSTRUCTIONS
Plaintiff client A….. B….., 06… Plate No…. October 1) The vehicle (a photocopy of the license is presented in the October of the petition)../../…. In the course of its history, moving from the direction of Batıkent to Ostim, the defendant C….. E….plate number 06 …, which belongs to ‘… Modelling …. Brand tool , ……………………. He was involved in a traffic accident with property damage at the intersection.
The defendant in the conduct of 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, the vehicle with the license plate number 06 … belonging to the defendant is fully defective. The defendant caused the accident by violating Articles 52/1-a and b of the Highways Traffic Law No. 2918. According to these articles
“Drive:
a) Reducing their speed when approaching intersections, entering turns, approaching hill tops, moving along turnpike roads, approaching pedestrian crossings, level crossings, tunnels, narrow bridges and culverts, entering construction and repair areas,
b) They must adapt their speed to the load and technical characteristics of the vehicle they are using, the conditions required by visibility, road, air and traffic conditions.”
As stated in the minutes, the defendant is the main one who is defective in the incident, and the plaintiff client has no defects in this accident.
Due to this accident, there are major damages to the client’s vehicle. As of this case, the client’s unusable vehicle is still…….. Ostim Yenimahalle is located at the address of Ankara …. It is located in the Auto Repair Shop.
Of grievances in order to ensure that the client is fixed, we can file a lawsuit against the side of the defendant; the amount of damaged parts of the vehicle, these damaged parts and repair labor costs, and depreciation of the value of the loss occurring in the vehicle, the vehicle will become available and how much it will cost within the period occurring within this period we determined that the absence of demand.
LEGAL REASONS: KTK, HMK, Law on Advocacy No. 6047 and other relevant legislation
EVIDENCE : A photocopy of the vehicle’s license, …/…/Dated 2021 ….. Accident Sequence Number, Material Damage Traffic Accident Identification Record, witness, expert witness and other all delail
CONCLUSION AND REQUEST : For all the reasons explained above, the 06 … License plate number owned by the client is …. Modelling …. We request by proxy to determine the amount of damaged parts in the brand vehicle, the repair and labor costs of these damaged parts, the loss of value and depreciation incurred in the vehicle, how long the vehicle will become available and how much the cost of absence occurring during this period will be. 23/11/2021
PLAINTIFF/ASSESSOR/ASSESSOR
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