… FAMILY COURT JUDGE
PROSECUTOR :
TC IDENTIFICATION NUMBER :
ADDRESS :
ATTORNEY :
(
Legal representatives of the parties, if any )
ADDRESS :
(
Legal representatives of the parties, if any )
DEFENDANT :
ADDRESS :
SUBJECT :
It is our petition that includes our requests for divorce, alimony and compensation for committing a crime.
CASE VALUE :
(
In cases related to property rights )
INSTRUCTIONS :
1-)
Our client married the defendant’s wife on his / her / her date. October follows from the family population register presented in the appendix (October 1), the parties have children from these marriages … and … in their names…. One of the children is … and the other is … old and both are small.
2-)
The defendant’s wife was arrested for the crime of sexual abuse of a child on which she had been thrown out of the Criminal Court of the High Criminal Court. / … E. As a result of the trial conducted on file No. 1, the said court …/… K. in accordance with Article 103/2 of Law No. 5237, he was sentenced to a three-year prison sentence. Although the decision in question was appealed in the defense of the defendant’s spouse, it was finalized on the date of …/…/… passing the approval of the Supreme Court (October 2) .
3-)
The said conviction disgraced the defendant as well as our client in front of third parties, our client had to leave the province where he lives with his children and the defendant and settle with his parents. Considering that the abused minor is a neighbor’s child, the situation becomes fantastically bad for our client. This october will be clarified by the statements of our witnesses, whose names and addresses are included in the list of witnesses presented in the appendix (October 3), to be given before your court.
3-)
Our client is a housewife and does not have any income. At the moment, he remains with his children, next to his own parents. Since the economic situation of her parents is not good, she cannot get enough support from them. Both of the joint children are still young and in need of maternal care and attention. Moreover, since the defendant’s wife is already in prison, there is no one else to take care of the children. Therefore, during the course of the case, we demand that a total of TL alimony be decided for our client, TL for each child, and that the joint children be decided to stay with our client for the duration of the case.
6-)
In addition, for our client, who was forced to terminate his marriage for the reasons we are trying to explain and was dragged into a very difficult situation in public, we are demanding a total of TL compensation, including TL material, TL spiritual.
LEGAL REASONS :
4721 P. K. m. 163, 168, 169, 174, 175, 182, 4787 P. K. m. 4, 6100 P. K. m. 240, 266.
LEGAL EVIDENCE :
A sample of the family population register, a photocopy of the population certificate, an annotation to the final … .. The history of the Supreme Criminal Court … / … / … / … E. …/…. K. court announcement, witness statements.
CONCLUSION AND REQUEST :
We have tried to explain the above reasons, our client to stay with their children during the divorce trial, the parties of the joint, the couple deciding to divorce in case of provision of custody our client our client for the joint monthly … … … TL TL TL month for each child and a total of liens in the amount of child support, alimony after divorce, poverty, and child support for her, as the continuation of our client in favor of TL financial…, … spiritual TL, TL recover total … , we request by proxy that a decision be made to transfer the costs of the trial and the attorney’s fee to the defendant party. …/…/…
ECLAIR :
1.
A sample of the family population registration and a photocopy of the identity card,2.
The final comment is … .. The history of the Supreme Criminal Court … / … / … / … E. …/…. K. court article, 3.
The list of witnesses shows the names and addresses of the witnesses and the subjects they will testify to,
4. An example of an approved power of attorney that includes one special authority.
Acting Plaintiff
Lawyer