TO SİGORTA ANONİM COMPANY
DEMANDING :A….. B….. (T.C.:…………….)
ADDRESS
ATTORNEY:
ADDRESS
PLATE NO:06 …
CAUSE OF THE ACCIDENT
GIVEN INSURANCE: C….. D….. (T.C.:……………)
POLICY NO: …………….
PLATE NO:06 …
SUBJECT OF THE REQUEST: The vehicle with license plate 06 … belonging to the client and the vehicle with plate number 06 … belonging to your company’s insured C….. D…… It consists of our material and moral compensation claims for the damage suffered by the client due to the traffic accident he has been involved in.
DESCRIPTIONS
Applicant client A….. B….., 06 … Plate numbered …. Mediator (copy of license is attached to the petition Annex-1) and ../../…. While moving towards Ostim from Batıkent direction in its history, your company’s insured owner belongs to C….. D…. Plate numbered 06 …. Model …. With the brand vehicle, ……………………. He was involved in a traffic accident with material damage at the junction.
The vehicle under the management and administration of C….. D…. could not stop by violating the speed limit rules of the location where the accident occurred, and quickly collided with the vehicle under the management and administration of the client, causing the client to crash into the vehicle in front, thus causing a chain injury traffic accident.
As a result of the incident, a Traffic Accident Detection Report (Appendix-2) was kept. According to the defect report (tramer) prepared in line with this report, the vehicle with license plate 06 … belonging to your company’s insured C….. D…. is the one with full and essential fault.
The plaintiff client has no fault in this accident. The client was trapped inside the vehicle and his right leg was broken. The client had to be operated on; He subsequently received physical therapy. The client had to cover the hospital and treatment expenses out of his own pocket. Invoices and documents related to these expenses are attached to this petition. (ANNEX-3)
The policy of the vehicle that caused the accident that caused the client to suffer this loss was made by your company. Pursuant to the General Conditions of Compulsory Financial Liability Insurance, the insurer is jointly and severally liable for material and bodily damages given to third parties by the insured, provided that they remain within the coverage limits. The client could not work during the treatment process; temporarily incapacitated. However, since the loss of value in the client’s vehicle as a result of the accident also constitutes a material loss item in economic terms, these losses must be directly compensated by the insurance company. Again, according to Article 1429 of the same law, the Insurer is obliged to indemnify the damages arising from the negligence of the insured, the insured, the beneficiary and the persons for whom they are legally responsible, unless there is a contract to the contrary.
For all these reasons explained, without prejudice to our right to claim and sue due to the accident; As a result of the accident, we demand that the client’s health expenses and financial compensation due to loss of earnings due to inability to work and moral compensation due to the negative effects of the accident be calculated and paid to us. We warn you that the payment should be made to the IBAN number stated below within 15 days from the date of notification of the application, otherwise we will go to court.
LEGAL REASONS :
EVIDENCE: Photocopy of the vehicle’s license, Traffic Accident Detection Report with ….. Accident Sequence Number dated …/…/2021, Invoices and documents related to treatment expenses, witnesses, experts and all other evidence.
RESULT AND DEMAND: For all the reasons explained above; without prejudice to our rights of lawsuits and claims regarding surplus;
As a result of the accident, the client’s health expenses and financial compensation due to the loss of earnings due to his inability to work and the moral compensation due to the negative factors caused by the accident will be calculated and the client’s ….. Bank TR .. …. …. …. …. …. We request that the client’s grievance be removed by proxy by sending it to the IBAN account numbered .. 29.11.2021
DEMANDING ATTORNEY
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