Petition For Trinket Receivable Lawsuit
-SAMPLE PETITION-
ANKARA FAMILY COURT ON DUTY
REQUESTER :
ADDRESS :……
AGENT :
ADDRESS :
TELEPHONE :
DEFENDANT :
ADDRESS :…
CASE VALUE : ………. TL
SUBJECT OF THE CLAIM :
It consists of the client’s claim for jewellery receivable due to the dissolution of the marriage union.
EXPLANATIONS
The client and the defendant ../../…. The client and the defendant were married on the date of .././ and they have no joint children from their marriage. Since the date of their marriage, the client and the defendant have been living together at ….. They have been living together in the family residence at the address of Batıkent Yenimahalle Ankara.
There has been a long period of incompatibility between the parties and there are frequent violent fights. ../../…. On the date of …/./, an argument started again between the parties; this argument escalated to verbal and physical violence. After this last argument, the client was forced to leave the house by the defendant.
As a result of the physical and psychological violence and the pressure to leave the house, the client had to flee from the house. We have filed a contested divorce case with Ankara … Family Court file no. 2022/… (Annex-1) and the proceedings of this case are still ongoing.
The client had the opportunity to buy only a few pieces of clothing and personal belongings in a short time. Many items and jewellery belonging to the client have remained in the family residence in which the defendant is staying and are not being delivered to the client. The client, who had to leave the possession receivables subject to this case at home, suffered a great financial victimisation.
The jewellery items in question and their values are as follows:
1-…..
2-….
As a result of all these explanations, it has become necessary to demand the return of the above-mentioned jewellery belonging to the client and remaining with the defendant to the client with this lawsuit.
LEGAL GROUNDS :
TMK, HMK, Attorneyship Law and other relevant legislation
EVIDENCE :
Photos and video recordings of the wedding ceremony, Ankara … Family Court file numbered 2022/… Esas, witnesses, experts, discovery and all other evidence
CONCLUSION AND DEMAND :
For all the reasons explained above; without prejudice to our rights to demand more;
1- Acceptance of our lawsuit and return of the jewellery items subject to the lawsuit from the defendant to the client,
2- If the jewellery items subject to the lawsuit cannot be found exactly as they are, the cost ………. TL to be taken from the defendant with legal interest and given to the client,
3- We request by proxy that the judicial expenses and attorney’s fee be decided to be left on the defendant. 13.01.2022
REPRESENTATIVE OF THE PLAINTIFF A… B…
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