TO THE COURT OF FIRST INSTANCE
Plaintiff: First Name and Last Name
Address:
Attorneys:
Address:
Defendant: First Name and Last Name
Address:
Subject: … TL; regarding a claim for compensation due to loss of livelihood.
Instructions
On …/…/…, the vehicle with license plate …, in which our client’s spouse, the Deceased, was traveling, collided with a vehicle with license plate … driven by the Defendant, which was traveling in the opposite direction at the relevant point on the highway, resulting in the Deceased’s death.
…In the criminal case heard before the First Instance Criminal Court regarding the incident, the expert report submitted determined the Defendant’s degree of fault to be …%.
Our client has been working as a trustee at the… Institution since … and earns a monthly salary of … TL. The defendant is a housewife and has no income. As of now, her sole source of income was her deceased husband, and with his death, our client has been left completely without support.
4. For the reasons stated above, it has become necessary to file this lawsuit to seek TL in compensatory damages from the defendant and to have this amount paid to our client; however, we reserve our rights regarding any amount in excess of this.
Legal Evidence: Inheritance declaration, … First Instance Criminal Court Case No. …/.. E., expert report submitted in the criminal case file, witnesses,. Population records, and all other types of evidence.
Legal Basis: Turkish Civil Code Article 45 and relevant legislation
Conclusion and Request: For the reasons explained above,. Our rights to any excess amount remain reserved. We request that the compensation arising from the lack of support be collected from the defendant, and that the litigation costs and the attorney’s fees to be paid to the opposing party be paid.
Prosecutor
Attorneys