… THE PRESIDIUM OF THE CRIMINAL COURT OF PENAL SERVITUDE
PLAINTIFF : (ID No: )
address :
attorney :
address :
DEFENDANT :
ADDRESS :
SUBJECT :Due to unfair detention ….-TL consists of our request for material and …-TL non-pecuniary compensation.
descriptions
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other defendant asked the bank’s employees to return the card, saying that the card was not in the atm, the money was withdrawn recently, our client complained unfairly, which led to a search and surveillance of his locker and at work, and a judicial investigation was launched against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.
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 in which he worked and his closet during the investigation, he has been humiliated in front of his colleagues, he has felt under psychological pressure. Moreover, since our client was unable to go to his workplace during the time he was detained, there were deductions from his salary until the day he did not leave.
3-) In order to ensure that the defendant is compensated for the material and moral damages arising from unjust detention for the reasons we have explained, it has been 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. for a total compensation of …-TL, including non-pecuniary, from the date of …-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