… TO THE JUDGE OF THE COMMERCIAL COURT OF FIRST INSTANCE;
PLAINTIFF: (TC no):
address :
attorney :
address :
DEFENDANT :
SUBJECT : Born from an Insurance Policy … TL. it is our petition that includes our collection request along with the legal interest you will receive.
OUR EXPLANATIONS
1- The …brand … model vehicle belonging to the client … /… /… was insured by the defendant insurance company with the Insurance Policy numbered … on the date of …/… /… as a result of the traffic accident he had on the date of pert and became unusable.
2- According to the traffic accident minutes, my client was 70 promil alcoholic at the time of the accident, but the cause of the accident is not that the client was alcoholic, but that the driver of the other vehicle involved in the accident violated the prohibition of turning. Although compensation for the damage was requested with the notice drawn to the defendant company after the accident, our request was rejected with the claim that my client was drunk at the time of the accident and the damage was excluded from the guarantee. However, according to the relevant provision of the Insurance Policy, in order for the damage to be excluded from the coverage, the accident must have occurred solely because my client was an alcoholic. Since the condition in question was not fulfilled in the incident and this issue was fixed with the accident minutes, the resulting damage is covered by the guarantee.
3- For the reasons we have explained, the insurance arising from the Insurance Policy … TL. the defendant company has been obliged to file a lawsuit to ensure that the damage is covered together with its interest at a rediscount rate from the date of default.
LEGAL REASONS :6102 p. K. m. 1027, 1029, 1265, 1409, 1410, 1420, 1421, 1424, 1425, 1427, 1446, 1453, 1461, 1465, 1472; 5684 P. K. m. 14; 2918 Pp. K. m. 85, 91, 99, 110.
LEGAL EVIDENCE :
Results and PROMPT : written above own-brand vehicle model nedenlerlemuvekkil …/…/… pert as a result of a motor vehicle accident that occurred due to the damage on it is the price of automobile insurance based on the number of TL …our insurance policy, the defendant insurance company to be reimbursed with interest from the date of the applicable interest accruals by default, litigation costs and attorneys ‘ fees we respectfully request that the court will be decided by the defendant from yukletilm. …/…/…
ADDITIONAL :
1-) … brand … model vehicle license,
2-) …/…/… dated Insurance Policy,
3-) Accident Detection Minutes,
4-) Caveat,
5-) Copies of responses to the warning,
6-) Expert examination
Plaintiff Attorney
Lawyer.
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