… 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: This is our petition, which includes our requests for divorce and alimony due to mental illness.
INSTRUCTIONS :
1 -) Our client married the defendant’s wife on the date of…/…/…. October follows from the family population register presented in the annex to our petition (October 1), the couple has two children from these marriages … and … named after them. One of the children is … old, and the other is … old, and both are small.
2 -) Some time after the marriage of the couple, there have been a number of changes in the habits and behavior of the defendant spouse. So much so that the defendant spouse began to exhibit behavior that became increasingly unstable, to have serious difficulties in making decisions on any issue, and to feel and experience some things that did not really happen, as if they really happened. Meanwhile, an intense forgetfulness has also begun in the decedent spouse, which has never been seen before.
3 -) Upon developments, the defendant wife, who underwent a serious health screening at the initiative of our client, was diagnosed with…. … Psychiatric hospital, Health Care Management edited by the report (Annex 2), as is evident from the name last illness, an incurable disease, medically accurate, but can be kept under control at a certain level. In the mentioned report, it is also clearly stated that the defendant spouse should be kept under supervision for a certain period of time.
4 -) Due to this situation, the couple’s joint life has become increasingly unbearable. This negative situation in which the defendant spouse falls into, even poses a serious danger from time to time from the point of view of joint children who are still young. This last point will be clarified by the statements of our witnesses whose names and addresses are written in the witness list (October 3), if your court deems it appropriate, regarding the subject. Moreover, both of the joint children are still young and need maternal care and attention. Therefore, we demand that the joint children stay with our client for the duration of the case, and that their custody be given to our client when it is decided that the couple will divorce.
5 -) Our client is a housewife and does not have any income. At the moment, he remains with his own parents, together with his children. 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. 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 -) For the reasons we tried to explain above, it was necessary to open this case.
LEGAL REASONS : 4721 P. K. m. 165, 168, 169, 175, 182, 4787 P. K. m. 4, 6100 P. K. m. 240, 266.
LEGAL EVIDENCE : A sample of family population registration, a photocopy of an identity card, a report dated…/…/…, witness statements, expert examination.
Results and PROMPT : for the reasons we have tried to explain above, the parties joint divorce our client to stay with their children during the trial, 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 the child support as her continuation, 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. …/…/…
APPENDICES 1.OCTOBER 2014 A sample of the family population registration and a photocopy of the identity card,
…/…/… date …. Your mistake … the numbered report,
The names and addresses of the witnesses and the topics they will testify about
the following is a list of witnesses,
An example of an approved power of attorney that includes one special authority.
Acting Plaintiff
Lawyer