Petition for Child Benefit Compensation
THE COURT OF FIRST INSTANCE
prosecutor:
LAWYERS:
DEFENDANT : Ministry of Interior
SUBJECT OF THE CASE : Compensation (…… TL).
INCIDENTS : 1- Plaintiff client …………. It is registered at the address. province, …………… District, Volume No: …………, S.No: …………….., his wife …………….. with ……… Married in the year and has three children from this marriage, …. At the age of ……. at the age of ……… and … at the age of …….. At the age of
2- Client ………. While working as a worker in his company. He normally received child benefit from the birth of each child. However, during the transfer of the population records to the computer environment. The client’s child records somehow disappeared and it was shown that the client was childless.
3- ………. In order to receive child benefit on its date, the birth certificate must be submitted at the beginning of each year. The client ….. when he requested the birth records for the year, he saw that his children were not included in the records provided, and upon his objection, they stated that their records were transferred in this way, but it was possible to transfer them in this way. Correct them by filing a lawsuit.
4- The client did not receive child support for the period elapsed until he filed a lawsuit and corrected it, and therefore suffered financial damage. This damage is approximately the amount of the lawsuit ….. … Amounts to TL.
It has become mandatory to open this lawsuit for compensation for the financial damage suffered.
LEGAL BASES:
EVIDENCE : Old and new population records, children’s birth certificates, witness statements, translation of foreign records showing that the client received child support, expert examination and all kinds of legal evidence.
CONCLUSION AND REQUEST : According to the reasons and evidence presented above, our case has been accepted and from the defendant …….. TL financial compensation and the highest commercial interest from the date of commencement of the damage together ………….., We respectfully request and request that our right to request more be reserved, that the costs and attorney’s fee be decided to be paid to the defendant…/…/….
Plaintiff Lawyer
Lawyer ………………….
(SIGNATURE)
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