.. TO THE CIVIL COURT OF FIRST INSTANCE ON DUTY
Plaintiff:
ATTORNEYS:
DEFENDANT:
PRIOR VALUE TO THE CASE: 3.860,51-TL (without prejudice to our rights regarding the excess)
SUBJECT : Claims Case.
DESCRIPTIONS :
We are the plaintiff’s attorney in accordance with the attached power of attorney.
By proxy ..Cumhuriyet Mah. .. Chad. No:1/A ../.. is engaged in car rental business. The defendant wanted to rent a Hyundai brand i20 model … plate vehicle on .. ../../2018, and a Rental Agreement dated ../../2018 was signed between them (Annex-1: Signed between the attorney and the defendant ../../ Rental agreement dated 2018). Pursuant to this agreement, the vehicle was delivered to the defendant on the same day.
The defendant had an accident with the vehicle belonging to the attorney and was found 100% defective as a result of the accident. As a result of this accident, 2,750,51-TL damage occurred on the vehicle (Annex-2: Invoice with Waybill). As a result of the accident, the vehicle remained in the service for 4 days, and the attorney made 700.00-TL expenses due to the fact that the vehicle remained in the service for 4 days and went to the service to check the vehicle.
Due to this accident, the 15% no claim discount within the scope of the vehicle’s insurance was canceled and the attorney lost his right to no claim discount, which he could use in the next period. If this accident had not occurred, the traffic insurance of the vehicle would have decreased from the 4th Stage to the 5th Stage, and this would have resulted in a minimum 400.00-TL discount on the relevant insurance fee in the next period. This issue will be clearly seen when the insurance policy is examined.
Considering all these issues explained in detail above, the necessity of filing this lawsuit has arisen.
LEGAL REASONS: TBK, HMK, TTK and relevant legislation
EVIDENCE:
Rental agreement signed between the attorney and the defendant dated ../../2018 (Annex-1)
Invoice with Waybill (ANNEX-2)
Discovery and expert examination,
Witness statements, oaths and any other evidence.
RESULT – REQUEST:
For the reasons explained above and to be taken into account ex officio, all kinds of claims and lawsuits regarding the surplus are reserved,
With the acceptance of our justified case, the cost of the damage suffered by the client due to the accident caused by the defendant is taken from the defendant and given to the client, as the cost of 3,860.51-TL,
By proxy, we request that the litigation expenses and fees be left to the defendant, and that a decision be made by proxy. Best regards.28.04.2018
Plaintiff’s Attorney
Hunting.
