Reply Petition For Compensation
THE COURT OF FIRST INSTANCE
CASE NO :
THE DEFENDANT:
lawyer :
prosecutor :
lawyer :
THE CASE : Compensation
SUBJECT : The Plaintiff ………. his deputy ………. our response to the dated lawsuit petition.
descriptions
My Client …………. The plaintiff, despite being a specialist physician, has filed a lawsuit for material and moral damages against my client, claiming that he and his wife have left as a representative of an identity that protects both human relations and medical ethics in the context of human relations. with ………. that he deceived himself and that this deception exists in some documents; Due to the unfounded nature of the claim, as we will explain below, there is no evidence to justify supporting the compensation claim with documents, and in the light of our explanations below and the documents supporting these explanations, it will be seen that the compensation claim is justified. it is unfair and unjust.
So
1- In the plaintiff’s petition, as if for a comfortable meeting between my client and his own wife, ……. By providing membership to the Club mentioned in the petition under the pretext of a match ……..although he stated that he went to either and met his wife here;
As can be seen from the attached document, my client attended a medical congress held on the dates of the alleged earlier ……….Oct. and at the end of the congress, he bought tickets to the match because of his passion for football. I’m asking as a viewer. The document showing my client’s participation in the relevant medical congress and participation on the specified dates has been presented.
2- Although the plaintiff used an expression in his petition as if his wife was a resident of Turkey, we believe that it is natural for the plaintiff’s wife to show an address in the Izmir province, as far as we have learned from the outside, because the plaintiff’s wife is a citizen of Turkey, her parents reside in ……. This sentence has no defensible logic.
3- The fact that the plaintiff’s wife took a protection decision during the marriage has nothing to do with my client. This issue is entirely related to the events that took place between the plaintiff and his wife. Dec. If the plaintiff’s wife has been subjected to any violence or psychological pressure by her husband, as stated by the plaintiff, there is also a divorce case filed in this regard. It seems that the plaintiff’s wife felt the need to take a decision to protect and therefore applied to the Family Court and obtained such a decision. This incident has nothing to do with my client’s alleged action.
4-We believe that my client has requested …….. TL …….spiritual ……. financial compensation from my client, claiming that he has suffered damage due to breach of loyalty debt in accordance with the provisions of the Code of Obligations in respect of the deceived spouse, but we believe that there is no provision for this request in the law and its conditions have not been established……… TL…..
5-My Client ………. he has never traveled to the country in his entire life……….. As can be seen from the document we submitted on the alleged dates …….. he went to attend a medical congress. He has made efforts in this regard, despite the very difficult conditions imposed by the British administration, especially on the visa issue, he received his visa due to the medical and medical congress and for a while ……..he must have gone to . ….) day.
By the way, my client is the plaintiff’s wife, whom he has previously known within the scope of humanitarian assistance Dec. ……….. he made a phone call with him in order to visit and see historical sites and his passion for football, especially in the context of where to visit and where to visit, and his passion for football. …………. where to enter, ……….. how and where to enter and as soon as possible with the guidance of the plaintiff’s spouse ………’ he has visited the relevant places in the.
6 – The issues alleged in both the Civil Procedure Law and the Criminal Procedure Law must be proved with material, conclusive and convincing evidence. In the absence of evidence, material and moral compensation cannot be awarded. In this regard, the issues in the plaintiff’s petition have collapsed in the context of the documents and there is not even a provision. There are no documents, photographic images, any information obtained through communication or documents proving that my client and the plaintiff’s wife stayed together in any accommodation facility.
We believe that the plaintiff filed a lawsuit on behalf of my client for this reason by resorting to slander in order to justify himself and strengthen the divorce case he filed to justify his restlessness and lack of livelihood with his wife. Also my client ………….. the plaintiff’s wife ………’ he has never been to the house where nin lives with him, he does not even know where he is.
Jul, perhaps in the inner world of the plaintiff, in the context of such humanitarian assistance (club membership and ticket supply), the plaintiff has filed a lawsuit for damages by subconsciously fictionalizing the humanitarian contribution that his wife provided for my client, based entirely on interpretation, slandering my client without any basis, thinking that his wife was unfaithful. (We also state that we reserve the right to file a lawsuit against the plaintiff as a result of the judicial process.)
Whether or not the conditions for material and moral compensation have been established, whether or not the plaintiff has a right to compensation, we wish your Court to evaluate the documents showing the contrary of the alleged issues and come to a conclusion in the light of these documents. .
In particular, your Court is aware that a person has the “right not to be contaminated”, which is a universal rule of law, as in civil and criminal cases.
In this context;
As the esteemed lawyer Sami Selçuk stated in an article; (Milliyet Newspaper, 10.02.2009)
“… The self-respect and honor of the suspect should not be damaged. People suspected of committing crimes should not be injured or tainted. The (preliminary) investigation should never turn into a show of force.
…
Even being brought to an open trial hurts people, damages their self-confidence. For this reason, some countries have adopted the right of appeal against the procedure leading to a trial (indictment or final decision to open an investigation) before an open hearing. Of course, the lack of such a remedy cannot be an excuse for the damage to people’s self-confidence…
…
Also, the exercise of authority can be nice. It can also be ugly. Ugly should not be preferred to beautiful. It can be moderate or strict, and strict should not be preferred to moderate. The principles that humanity has experienced since the Roman law should be followed. ‘Rigidity is very close to injustice, and no one can be deprived of legal protection/justice’…”
In addition to the fact that the unfounded statements made by the plaintiff about my client have no basis, it is understood that the plaintiff resorted to this method to justify his lack of livelihood with his wife and the divorce case he filed. In addition, the marital relationship between the plaintiff and the defendant has ended, and Decrees of protection were issued to the plaintiff’s spouse long before the alleged incidents. My client’s acquaintance with the plaintiff’s wife is an acquaintance within human limits.
In order to support our explanations, we submit each document we summarize below to your Court’s discretion and evaluation.
In this context
a-) “………..” My client’s “………. a photocopy of the invitation to attend the medical congress called “. recent developments in cancers” titled article, ……….. It proves the invitation to the dated medical congress.
b-) A photocopy of the round-trip plane ticket to the congress on the dates in question.
c-) Reference information about the promotion in line with the purpose of the Congress. The document shows the content of the program and …………’ It is the document that belongs to E.
d-) In the same way ………. after the date, my client …………… He attended the match. the next day ……………. Because of his passion for football, my client wanted to go to the match to be played after the end of the congress days and in this context since his membership in the club………. The match was played at the address. In order to make a reservation, the information section showing the Arsenal club membership (Match tickets) and how the ticket was purchased is mandatory. This document is taken from the club’s website ………. However, the document showing the club membership was torn up and destroyed by the plaintiff.
The way in which this happens is as follows.
My Client ………….. On one occasion, my client, within the framework of humanitarian friendship, told the plaintiff’s wife that he would attend the medical congress on the dates mentioned above, since the plaintiff’s wife had been living in England for many years.
He has known this country very well for many years and at the end of the congress, he provided the plaintiff’s wife with tickets to this match, saying that he wanted to attend the match in question, so he needed a membership to book, he asked her to help him in this context, the plaintiff’s wife conveyed her desire to help him in a humanitarian framework, and when he was interested in Arsenal club membership, the plaintiff’s wife left her home in London and came to Turkey for a day because her parents were in ……Jul, the plaintiff’s wife, who was about to leave the house because her tickets stayed at her home in England ……, He saw the ticket and the card showing the club.
when he and his cousin emptied all the belongings of the house and left the house, he tore up the ticket and the club membership card and destroyed it.
The plaintiff’s wife ……….after returning to, she saw that her belongings had been taken away, her husband had left the house, the house had been left untidy, her club membership card and the ticket she had bought on behalf of the defendant had been torn up, and because of this picture she had seen, the plaintiff’s wife had applied to the police for identification purposes, since the house had been evacuated.
While this situation continues, my client ………… English speaking, he spoke English, he is a doctor and he came from abroad, although they told him that maybe I could go to the match, he went to the stadium where the match was played again, thinking that he did not have a membership card, so he could not enter the match, he did not even have a ticket, by the way, my client expressed his desire to go to the match, the authorities here showed tolerance and allowed my client to watch the match by allowing the players to enter the stadium, not the stadium where the normal spectators came. He did not have a membership card, so he could not enter the match, even though he did not have a ticket. He spoke English Decently, he was a doctor and he came from abroad.
Within the scope of the documents, my client’s participation and invitation to the congress in question ………. Was made by the pharmaceutical company and an invitation letter written in Turkish was submitted.
Also, ………. Dec paying the accommodation, congress attendance and air ticket prices between the dates ……… Titled document and the document showing that the bed and breakfast fees were paid were also presented.
The document showing the departure and return flight hours of my client,
Your Payments ……….. a document showing that it was met by,
A document entitled “Pre-Pait Accommodation” was presented, indicating that the re-booking was made and payments were made.
A document showing the location of the hotel, as well as a document showing that my client stayed at the hotel,
Result and demand; for the reasons explained above;
Since there is no evidence supporting and documenting the plaintiff’s claims. I request that the case be dismissed and that the decision be made to leave the trial expenses and attorney’s fees to the plaintiff.
I want to convey this request. Kindest regards,
The Defendant’s Lawyer
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