TO THE HONORABLE COURT
…….
PLAINTIFF: …….
ATTORNEYS: …….
DEFENDANT: …….
SUBJECT: Damage Assessment
EXPLANATIONS:
1-Our client ……., while driving his vehicle with license plate number ……. on ……. at approximately ……. on ……. within the boundaries of ……. while traveling normally in the direction of ……. was involved in a traffic accident resulting in material damage when the vehicle with license plate number ……. belonging to the opposing party and driven by ……. entered the road from the left side of the road in an uncontrolled manner in the direction of travel.
2-While the other party’s driver was operating the vehicle with license plate number ……, our client’s vehicle was traveling normally, and the other party’s driver caused the accident by violating Article 47/1d of Law No. 2918 with the primary fault of “changing direction and making an improper maneuver,” and was found to be 100% at fault in the accident. Our client bears no fault in this incident. Our client’s vehicle is currently located at an address in an industrial area, which we will provide later.
3-This accident caused significant damage to our client’s vehicle.
Since we will be filing a lawsuit against the other party,
The cost of the damaged parts of our vehicle,
The repair and labor costs of the damaged parts,
Loss of value,
Depreciation loss,
The number of days it will take to restore the vehicle to its original condition,
Amount of absence costs
It has become mandatory to request that these be determined by an expert.
LEGAL BASIS:
HUMK., BK. KTK and Related Legislation
EVIDENCE: Traffic Accident Investigation Report,
CONCLUSION: For the reasons stated above, we request that the Court appoint an expert to determine the matters stated above, that the costs of such determination be borne by the opposing party, and that the opposing party’s attorney’s fees be paid to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney’s Law No. 1136, as amended by Law No. 4667.
ATTORNEY REQUESTING THE DECISION