Claim for Compensation for Damages Resulting from a Traffic Accident
TO THE HONORABLE COURT
Request for Interim Measures
…….
PLAINTIFF:…….
ATTORNEYS:…….
DEFENDANTS:…….
SUBJECT: Without prejudice to our right to claim additional damages and pursue further legal action, we request that the defendants jointly and severally pay the material damages of ……. with legal interest from the date of the accident and that a provisional measure be imposed on the registration of the vehicle with license plate number ……. as security for our claim.
EXPLANATIONS: 1-Our client…… The registered owner of the vehicle with license plate number..…. And the defendants…. …… The driver of the vehicle with license plate number.. … .. And …. ….., were involved in a traffic accident on ../../…. that resulted in material damage, death, and injury.
2-The incident occurred on ……. at approximately……. O’clock, when the vehicle with license plate……. Crossed into the opposite lane and collided with our client’s vehicle. As can be seen from the Traffic Accident Report, the other party is primarily at fault in this incident. They crossed into the opposite lane and collided with our client’s vehicle.
3-As a result of this accident, irreparable damage occurred to the vehicle with license plate ……. belonging to our client. Our actual damages will be determined as a result of the assessment we made with the ……. Civil Court of First Instance ……. D. İş.
LEGAL BASIS: Traffic Law, Code of Civil Procedure, Relevant Legislation
EVIDENCE:
Traffic Accident Report,
Traffic Records
Medical Examination and Specialist Examination
……. ACM ../…. E. File
……. AHM ../…. D. Case File
Witness Statements,
Legal and Discretionary Other Evidence, etc.
RESPONSE PERIOD: 10 Days
RESULT OF THE REQUEST: For the reasons stated, while reserving our right to sue and claim for excess amounts, the defendants shall be jointly and severally liable for the payment of ……. in material damages, with legal interest from the date of the accident, the defendants shall be liable for the costs of the proceedings, a precautionary measure shall be imposed on the registration of the vehicle with license plate ……. in order to secure our case, pursuant to the last paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Law No. 4667, we request that the opposing party’s attorney’s fees be paid to us as attorney’s fees.
PLAINTIFF’S ATTORNEY
…….