Petition For Separation Case
ANTALYA ON DUTY ( ) FAMILY COURT
THE PLAINTIFF :A….. B…. (T.C.:………..)
ADDRESS
AGENT :Lawyer …………….
ADDRESS
DEFENDANT :C….. B…. (T.C.:………..)
ADDRESS
SUBJECT OF THE CASE : It consists of the submission of our petition requesting a separation decision.
OUR EXPLANATIONS
Client A….. B…. and the defendant C….. B…. were married on 01.01.2010 and have joint children named X and Y from this marriage. Since the date of their marriage, the parties have been using ……………………….. They have been residing in the family residence located at the address of Batıkent Yenimahalle Ankara.
The parties spent the last two years of their marriage constantly arguing and fighting. Their marriage, which started well, later became unbearable for both parties. The parties tried every way to save their marriage and even wanted to stay apart for a while.
Believing that staying separated for a while would have positive consequences for themselves, their marriage union and their children, the parties decided to separate; defendant C….. B…. ../../…. He left the family residence on the date. In this process, the client wants to continue living in the family residence with her children.
The client’s income level is quite low compared to the defendant’s income level. The client, who will take care of the two joint children in this process, is in great need of financial support.
For all these reasons explained, we request your Court to decide on the separation of the parties and to award an alimony of TL 000.00 for each child and TL 000.00 for the client during the separation period.
LEGAL GROUNDS :
CPC, TMK, Law on Lawyers. and other relevant legislation
EVIDENCE :
SSI Income enquiry, Population records, witness, expert, oath and other evidence.
We reserve our right to present evidence against the evidence presented / to be presented by the other party.
CONCLUSION AND DEMAND :
For the reasons explained above and to be taken into consideration ex officio by your Honourable Court
1-Acceptance of our lawsuit and all our demands,
2-To issue a separation order for the parties for a period of …,
3- To give the custody of the minor joint children to the plaintiff client during the separation period and to establish a personal relationship between the minor joint children and the defendant C…. B…. To establish a personal relationship between
4-To award a precautionary alimony of TL 000,00 in favour of each of them as of the date of the lawsuit for the maintenance of the joint children,
5-To award the plaintiff client a monthly precautionary alimony of TL 000,00 as of the date of the lawsuit,
6-We request by proxy that all kinds of trial expenses and attorney fees be decided to be charged to the other party.14.01.2022
Plaintiff’s Counsel
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