Petition For Failure To Comply With Child Surrender
……. TO THE HONORABLE JUDGE
COMPLAINANT :…….
DEFENDANT :…….
ACCUSED :…….
CRIME : NON-COMPLIANCE WITH CHILD SURRENDER
EXPLANATIONS :
Our client and the defendant ……. on ……. ……. of the Civil Court of First Instance Main and ……. Decision numbered decision of the Civil Court of First Instance on .
2- During their marriage, their joint child ….., aged … was given to the defendant mother. The court decided that the father should see little ….. every weekend on Saturday between 11:00 and 16:30 in the morning.
3-Our client wanted to settle this meeting by agreement without involving the bailiffs, but the defendant refused to do so. Thereupon, the judgment was executed by our client on ../../…. on ../../…. on the date …… Enforcement Directorate ../…. E. and the defendant was notified of the 55 Sample Execution Order in this regard and finalized.
4-The defendant still refuses to comply with the judgment. Although our client went to pick up the child with the officer for 3 weekends, the defendant kidnapped the child on the grounds that he took the child to the doctor. Although he was notified to the enforcement file, he did not submit a doctor’s report.
5-We request that the defendant be punished for his criminal act according to Article 25/a and 341 of the BEC.
LEGAL GROUNDS : BEC Article 25/a and 341
EVIDENCE : Execution File, witnesses
CONCLUSION OF THE REQUEST :
For the reasons explained, we request that the defendant be sentenced, that the costs of the trial be charged to the defendant, and that the counterparty attorney’s fee be awarded on our behalf as a lawyer in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.
COMPLAINANT’S ATTORNEY
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