I. Information required for auto insurance prosecution:
Identity certificate, insurance contract, insurance accident and other supporting materials, basic information materials of insurance companies of both parties, etc.
Second, the indictment format:
Civil complaint (loss of vehicle property)
Plaintiff1:* *, male, ID card: address: * * *
Plaintiff 2: xxx Transportation Co., Ltd. Address: Jinwen Avenue, Wenzhou City Legal Representative: xx
Authorized Agent: * * *, lawyer's address * *, telephone number * * *
Defendant 1: X, male, ID address: * * *
Defendant 2: * * * Freight Forwarder Co., Ltd. Address: * * * * Legal Representative: * * *
Defendant 3: * * * Freight Co., Ltd. Address: * * *
Legal Representative: * * Tel: * * *
Defendant 4: * * Insurance Co., Ltd. * * Provincial Branch Address: * * Legal Representative: * * Claim:
1, and defendant I, defendant II and defendant III jointly compensated the plaintiff for vehicle maintenance costs of 58,938 yuan and assessment costs of 2,800 yuan;
2. Judge that Defendant IV shall be liable for compensation within the limits of traffic compulsory insurance and third party liability insurance;
3. It is decided that the above four defendants shall bear the legal costs of this case.
Facts and reasons:
At about April 29th, 2065438 15: 45, Plaintiff 1 drove Plaintiff 2' s Zhejiang C 13xxx heavy-duty semi-trailer in the direction from Huidong to Guangzhou on Guanghui Expressway. Defendant I was driving a heavy-duty semi-trailer with the license plate number of Guangdong AD 1233 on Guanghui Expressway, and the vehicle driven by Defendant I was heading from Huidong to Guangzhou in the same direction as the plaintiff. Due to improper operation of Defendant I during driving, Guangdong AD 1xxx vehicle collided with Zhejiang C 1xxx heavy-duty semi-trailer, which was confirmed by the accident certificate issued by the Second Brigade of Expressway of Traffic Police Detachment of Huizhou Public Security Bureau, and Defendant I was liable for compensation. After the accident, the plaintiff drove the vehicle to Guangzhou Youyida Commercial Vehicle Service Co., Ltd. (a first-class motor vehicle maintenance company) for maintenance, which is the only company in South China that is qualified to maintain this type of vehicle. During the maintenance period, the plaintiff entrusted Guangzhou Huameng Price Office Co., Ltd. to evaluate the loss price of the accident vehicle. After dismantling and inspection, the total loss price of the vehicle is 58,525 yuan (see Suihua Price Estimation (New) [20 10] xx). It was verified that defendant 1 was the driver employed by defendant 2 and was carrying out the transportation task assigned by defendant 2 at the time of the accident. The accident vehicle Guangdong AD 1xx heavy-duty semi-trailer is owned by Defendant 3, but has been used by Defendant 2. Therefore, defendant 2 directly purchased traffic compulsory insurance and third party liability insurance from defendant 4 as the insured. Now the plaintiff's vehicle has been repaired, and the accident has caused the plaintiff to lose 58,938 yuan. According to Item (5) of Article 58 of the Procedures for Handling Traffic Accidents? The repair cost and discount compensation cost are calculated according to the actual value or the appraisal conclusion of the appraisal institution. "The plaintiff failed to ask Defendants 2 and 3 to compensate for the actual losses. In order to safeguard the legitimate rights and interests of the plaintiff, we hereby file a lawsuit with your hospital, requesting your hospital to support the plaintiff's request.
I am here to convey
* * * District People's Court
Plaintiff: XXX