……. TO THE HONOURABLE JUDGE
REQUESTING AN INJUNCTION
COMPLAINANT WIFE :…….
AGENT :…….
AGAINST PARTY
DEFENDANT WIFE :…….
SUBJECT : Law No. 4320 on the Request for Measures Pursuant to Law No. 4320.
EXPLANATIONS :
Our client and the defendant spouse have been married since ……. and marriage records, ……. Province, ……. District, ……. Neighbourhood, ……. Volume No, ……. Family Sequence No and ….. Order No. The parties have a child named ……. born in …/../…. from this marriage.
Defendant spouse does not fulfil the obligations imposed on him by the marriage union and when our client reminds him of this, he resorts to violence. The defendant comes home late at night with alcohol and beats our client. The doctor’s reports regarding this are attached.
For these reasons, it has become necessary to make this application for your court to issue an injunction against the defendant spouse in accordance with Law No. 4320.
H. CAUSES : Law No. 4320 and Related Legislation
EVIDENCE : Doctor’s reports, Population Register, witness statements etc.
CONCLUSION OF THE REQUEST :
For the reasons stated above, we respectfully request and demand that the necessary injunction be issued against the defendant spouse in order to prevent domestic violence. …….
COMPLAINANT’S REPRESENTATIVE
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