TO THE HONORABLE COURT
…….
PLAINTIFF:
ATTORNEY:
DEFENDANTS:
SUBJECT: ………………….-TL, along with bank discount interest, expenses, and attorney fees, from the payment date of .. / .. / ….
FACTS: 1-The premises insured under insurance policy no. ……………… in the name of ………………………………………………………………………………………… at our company suffered damage as a result of a fire that broke out at the defendant’s workplace on .. / .. / ….
2-The damage compensation of ………………………-TL determined as a result of the expert assessment conducted at the insured premises has been paid to our insured.
3-With the payment of the damage, our company has become the successor to the insured in accordance with the terms of the contract and the provisions of Article 1301 of the Commercial Code, and all rights against those who caused the damage to the insured have been transferred to our company.
4-According to the minutes and expert report prepared regarding the incident, the defendant has been determined to be responsible for the damage that occurred. Since the defendant is liable to our insured and, consequently, to our company, which has taken the place of the insured, it has become necessary to file this lawsuit.
LEGAL GROUNDS: HUMK, BK, TTK, Traffic Law, and relevant legislation.
EVIDENCE : Policy, investigation report, expert examination, and all legal evidence.
RESPONSE PERIOD : 10 days
CONCLUSION AND REQUEST: As stated above, we request that the parties be notified and that, as a result of our case being proven, the defendant be ordered to pay ……………………………-TL, along with bank discount interest, expenses, and attorney’s fees, from the payment date of .. / .. / ….
Plaintiff’s Attorney
