[Insert Court Information] TO THE COURT
[Enter location information]
THE PLAINTIFF : [insert name]
REPRESENTATIVE : [Enter proxy information]
DEFENDANT : [insert name]
SUBJECT : Divorce due to adultery.
EXPLANATIONS :
1-My client is the wife of the defendant for 22 years. They have 6 children from their joint marriages. Marriage records are [Insert Province] Province, [Insert District] District, [Insert Neighbourhood] Neighbourhood, [Insert Volume No] Volume No, [Insert Page No] Page No and [Insert Registry Row No] Registry Row No.
2-The defendant is a market trader and from time to time he is out of the city and sells vegetables and fruits in markets and fairs. My client has been sewing at home for many years and contributes to the defendant’s wife and household expenses.
3-My client has been hearing for a long time that her husband is cheating on her. For some time now, the defendant has been coming home only on weekends and has told our client that he is busy at work and therefore has to sleep in the lorry from time to time. When this went on for more than 6 months, our client became suspicious and followed his wife. Our client, who saw that his wife regularly went to another house at [Insert address] in [Insert district information], learnt that his wife was living with another woman as husband and wife.
4-His wife was very daring in this regard and put her own name on the doorbell and had a telephone with the subscription number …………. installed in her name. Worse, our client learnt that his wife had a son with this woman. When our client asked his wife about the situation, the defendant did not deny it and accepted it.
5- The defendant is currently not staying with our client and her children. He uses the house at the above address with the other woman he lives with. The defendant’s cheating on his wife is fixed with his own statements, witnesses and his child from an illegitimate relationship.
6-We request that our client be granted a divorce from the defendant. We also request that [Insert amount] TL alimony to be converted into poverty alimony for our client and [Insert amount] TL precautionary alimony for each of her children.
LEGAL GROUNDS : Article 129 of the Civil Code and other legal legislation.
EVIDENCE : Population records, witnesses, DNA tests and all kinds of medical reports, other evidence.
RESPONSE TIME : 10 days.
RESULT OF THE REQUEST: For the reasons explained, we request that the parties be divorced due to adultery, that the custody of the joint children be given to the plaintiff, that the monthly alimony of [Insert amount information] TL for the plaintiff and [Insert amount information] TL for each child be taken from the defendant, that the trial expenses be charged to the defendant, and that the counterparty attorney fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Law No. 1136 on Attorneyship amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
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