Law No. 5651 Prevention of Attack Detection of Content Removal Petition

TO THE CRIMINAL JUSTICE OF THE PEACE
Complaining
attorney :
Suspect : Unsolved
SUBJECT : The determination of the illegality of the attack on our client via the Internet consists of our request to stop and remove the publication.
descriptions
1-) The photograph taken in close-up while the client was meeting with his close friends …./…/…. It has been published on various sites on the Internet in its history, through the company that the client and his friends are working on “… A.Sh. he makes these things work..”with the accusations in the form of, shares were made for the company where the clients work.
2-)As a result … A.Sh. they were dismissed by. The client is a person who has responsibility in business life and is a loved one in his immediate environment. Alcoholism is an excessive passion for alcoholic beverages in a way that harms a person’s physical and psychological health, and the fact that the client drinks one or two drinks while going out to dinner with close friends is referred to as alcoholism is contrary to reality, it is clearly an attack on the client’s personal rights. For this reason, the fact that the client has been dismissed also has irreparable consequences for the client.
3-) The client has been clearly victimized by the news that is an attack on the client’s private life and personal rights in a way that is easily accessible on the Internet. In this regard, Article 24 of the TMK No. 4721 regulates that a person whose personal rights are being attacked unlawfully may request protection from a judge against those who commit the attack.
4-) In the Internet environment ……with the publication made from the website, the respected personality of the client has been compromised. About this illegal publication …/…/….on the date of the application to the hosting provider, the content related to the client was requested to be removed from the publication, but our application was not responded to within 2 days after the request reached the hosting provider, and the publication was not removed from the relevant website. (October-3)
5-) With the removal of the publication containing unfair and untrue statements about the client from the Internet, it should be decided to publish the answer prepared by us on the Internet for a week in order to prevent damage to the client’s reputation.
6-) Due to the above-mentioned issues, we have been obliged to apply to your Honorable Court with the determination of the illegality of the attack made via the Internet, the request to stop and remove the publication.
LEGAL REASONS : 5651 P. K. m. 9, 9/A, 5237 P. K. m. 134, 4721 P. K. m. 24, 25, Regulation on the Procedures and Principles for the Regulation of Publications Made on the Internet, m. 10
LEGAL EVIDENCE :
1-) Photocopies of related website images
2-) Sample of the application petition made to the website hosting provider
3-) The witness list shows the names and addresses of the witnesses and the topics they will testify about
4-) Expert Examination.
CONCLUSION AND CLAIM : For the reasons we have explained above, in the concrete incident, our client’s personal right is clearly violated “……….. we respectfully request on behalf of our client to determine the illegality of the attack made via the Internet on the website called ”com”, to stop the publication and to decide on its removal. …/…/…
ADDITIONAL :
1-) Photocopies of related website images
2-) News clippings related to various newspapers.
3-) Sample of the application petition made to the website hosting provider
4-) The witness list shows the names and addresses of the witnesses and the topics they will testify about
5-) One approved power of attorney sample.
The Requesting Deputy
Lawyer.
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