TO THE HONORABLE COURT
…….
REQUESTING PARTY :…….
ATTORNEYS :…….
OPPOSING PARTY: …….
SUBJECT: Damage Assessment
EXPLANATIONS: 1-Our client ……., while driving the vehicle with license plate number ……. on ……. While traveling normally toward ……. within the boundaries of the town of ……. on the day of ……. at approximately ……. o’clock, the vehicle with license plate number ……. driven by ……. and owned by the opposing party entered the road uncontrollably from the left side of the road in the direction of travel, resulting in a traffic accident causing material damage.
2-The opposing party’s driver ……. while driving the vehicle with license plate number ……. while our client’s vehicle ……. was traveling normally, caused the accident by committing the primary fault of “changing direction and making an incorrect maneuver” and violating Article 47/1d of Law No. 2918, thereby being 100% at fault for the accident. Our client bears no fault in this incident. Our client’s vehicle is located at an address in the industrial area, which we will provide at a later date.
3-This accident has caused significant damage to our client’s vehicle.
As we will be filing a lawsuit against the opposing party,
The cost of the damaged parts of our vehicle,
The repair and labor costs of the damaged parts,
Loss of value,
Loss of depreciation,
The number of days it will take to restore the vehicle to its original condition,
The amount of the absence expense
It has become necessary to request that these be determined by an expert.
LEGAL GROUNDS: HUMK., BK. KTK, and Relevant Legislation
EVIDENCE: Traffic Accident Investigation Report,
CONCLUSION: For the reasons stated above, we request that the Court decide to have the matters mentioned above determined by an expert appointed by the Court, that the costs of the determination be borne by the opposing party, and that the opposing party’s attorney’s fees be awarded to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Act No. 4667.
ATTORNEY REQUESTING DETERMINATION
