Compensation For Losses Due To Theft From Insurance
TO THE HONORABLE COURT
PLAINTIFF:
ATTORNEY:
DEFENDANTS:
SUBJECT:……………………………………..-TL from .. / .. / …. payment date, …………………………-TL from .. / .. / …. payment date onwards (Total ……………………….-TL, subject to our right to claim any excess) together with bank discount interest, expenses, and attorney’s fees.
FACTS: 1-A theft incident occurred on .. / .. / …. at the insured workplace under insurance policy no. ……………… in the name of ………………………………………….
2-The defendant ………………………….., who committed the act, and ………… ………….., by failing to properly care for and supervise the minor under their custody ( ……….. …………….. ), caused our client to suffer damage. A lawsuit was filed against our company and the defendants by our insured ………………… at the ……………. Civil Court of First Instance on ……./…… E. Number, and in connection with the concluded case, …………………-TL was deposited into file number ……. on 04.07.2002, and an additional …………………-TL was paid on 21.07.2000, for a total of ……………………..-TL paid to our insured.
3-With the payment of the damage, our company has succeeded to the rights of our 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 report and court decision prepared in relation to the incident, the defendants have been found responsible for the incident. Since the defendants are 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, ……………… Civil Court of First Instance Decision No. 2000/503 E., ……./……. K, 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, ………………………………………-TL be paid on 04.07.2002, …………………………… -L on 21.07.2000 (with the reservation that our rights to claim the excess amount of …………………….-TL remain reserved) along with bank discount interest, expenses, and attorney fees. …….
Plaintiff’s Attorney
…….
