… THE PRESIDIUM OF THE CRIMINAL COURT OF PENAL SERVITUDE
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT :Due to unfair detention ….-TL material and …-TL spiritual
it is our petition that includes our request for compensation.
INSTRUCTIONS
1-) The defendant …../…./…. On his date, he asked our client’s help to withdraw money from the ATM, but when the card was blocked, the other defendant asked the bank’s employees to return the card, saying that the card was not in the atm, the money was withdrawn recently, our client complained unfairly, which led to a search and surveillance of his locker and at work, and a judicial investigation was launched against him. (APPENDIX – 1)
2-) Our client is at the workplace where he works …. he has been working in his status and has been in a difficult situation due to the search of the environment and his closet where he worked during the investigation, and he has been humiliated in front of his colleagues. Moreover, since our client was unable to go to his workplace during the time he was detained, there was a deduction from his salary until the day he did not leave.
(APPENDIX – 2)
3-) In order to ensure that the defendant is compensated for the material and moral damages arising from unjustified detention for the reasons we have explained, it was necessary to open this case.
LEGAL REASONS : 5271 P. K. m. 91, 92, 118, 141.
LEGAL EVIDENCE :
1-………… The File of the Investigation of the Numbered Prosecutor’s Office and the decision to detain
2-Workplace identity file
CONCLUSION AND DEMAND : For the reasons described, the total for the period of our client’s unjustified stay in custody is …-TL. – and …-TL. as of the date (the interest claim may vary depending on the date of detention or lawsuit), the total compensation, including non-pecuniary …-TL, will be …-TL. we respectfully request on behalf of our client that it be decided that the interest will be dominated, the trial costs and the power of attorney will be charged to the opposite party. …/ …/ …
Deputy Plaintiff