Petition for Compensation for the Liability of the Building Owner
THE COURT OF FIRST INSTANCE
(Precautions requested)
Plaintiffs:
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Lawyers:
Defendants :
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Lawsuit : Without prejudice to the rights to redundancy, for the spouse and children who are deprived of alimony ……….. a request for a decision on financial compensation to be determined in accordance with the article. Who lost his life as a result of a concrete block falling on him from the building he was passing by.and total ………. TL. It has been decided to apply an injunction to collect the moral compensation from the defendants jointly and jointly and to be paid to the plaintiffs along with the interest, trial costs and attorney’s fees to be operated from the date of the incident. Issuing an injunction decision on the movable and immovable property of the defendants and their rights and receivables from third parties.
The main value of the fee is : …….. TL for financial compensation ………. TL for moral compensation
Descriptions
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……… in the history of …… in the accident that occurred on the date , the driver of the pickup truck …….. He lost his life as a result of a concrete block falling on a pickup truck from the upper floor of the building he was passing by plaque …………
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……….. ………. in the Expert Report submitted to the numbered investigation file C. The Prosecutor’s Office ………. in his decision, it was determined that the building owners were 100 percent defective on the grounds that they did not take the necessary measures during the demolition of the illegal floor in violation of the Zoning Law. (Accident minutes, statements, expert report)
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………. Who lost his life as a result of a concrete block falling on him, ……..d.lu (….), he was making money with his truck by doing the transportation works of the company owned by his relatives. With his death, his wife and children were deprived of financial and moral support. In addition, the parents of the deceased teenager also lost the moral support of their son. (Family population chart, waybills related to the transportation business, truck license and driver’s license belonging to the deceased alimony, tax records)
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… the wife who is deprived of alimony ……… dd………, son …….. dd……… and the daughter …….. dd……… compensation and rights of deprivation of support have been requested for their redundancies are reserved. For this reason, we request that the court rule on the financial compensation to be determined in accordance with the article ………. together with the interest that will accrue from the date of the event. (Family population table)
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a )
Although it is more appropriate to determine the amount of moral compensation in such a way as to supplement it and deter the defendants depending on the evidence to be collected during and after the trial, compensation is determined according to the amount and scope of material compensation, and the amounts of moral compensation are explained below due to the uncertainty in the application and the shortness of the time-out period applied to the article.
b)
The one who lost his life as a result of falling on a concrete block from a runaway building belonging to the defendant company while passing on the road in his pickup truck …….. considering that there is no defect, the serious defect of the construction is that the owner company built illegal buildings and did not take the necessary measures during the demolition, his wife was too young, his children were too young, mom and dad lost their sons who provided financial support and took care of them untimely , for the wife …….. amount of moral compensation …….. For the wife ……… TL, for the son …….. ………, for a girl child ……… ……….tl , ……… TL for dad ………. and ……..tl for mom ……. Total ………TL for all plaintiffs. TL to all claimants.
Conclusion and claim: Without prejudice to our rights regarding redundancy, for the reasons shown:
Who lost his life as a result of a concrete block falling on him from the building he passed by …….. to the wife and children deprived of alimony of ……….. financial compensation will be paid, which will be determined according to the article. And the total ……….. TL. I request that an injunction be applied on the interest, trial costs and attorney fees to be accrued from the date of the incident, as well as moral compensation to be received jointly and in chains from the defendants and paid to the plaintiffs; movable and immovable property of the defendants, as well as rights and receivables from third parties.
I am submitting my request here. Kindest regards,
Plaintiffs’ Lawyer
Lawyer. ..
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