ANKARA SENTRY FAMILY COURT
PLAINTIFF: Name- Surname (T.C Identification Number)
Address
ATTORNEY: Lawyer Name-Surname
Address
RESPONDENT: Name-Surname (T.C Identification Number)
Address
SUBJECT: Divorce due to adultery, financial and moral compensation, custody and subsidiary child support is our petition for claim.
INSTRUCTIONS:
(This section should be filled in by taking into account the content of the concrete event within the scope of the procedure specified by the Legislator in the articles.)
1-) The parties were married on /…/… and have joint children from these marriages. One of the common children …. the other one is born and raised …. was born. The plaintiff’s profession is …… and his monthly income is … TL, and the defendant’s ……… and his monthly income is … TL.
2-) The marriage of the parties was shaken due to the complete imperfection of the defendant, and the marriage became unbearable for the parties. He found out that the defendant had been cheating on the plaintiff client for months and that she was having an affair with someone else. (The events related to the alleged matter in this section should be explained by giving evidence.)
3-) It will be fixed by the evidence submitted to the court that the defendant cheated on the plaintiff and will be collected.
For this reason, the parties should divorce based on the cause of adultery, the custody of joint children should be given to the client’s mother as a precautionary measure while the case is ongoing and final at the end of the case, the plaintiff should be given to the client …. TL financial, ……. TL per month for joint children with non-pecuniary compensation ………..’er TL while the case is ongoing, there has been an injunction and an obligation to open the relevant case so that it can be decided to pay child support to continue as a subsidiary child support at the end of the case.
LEGAL EVIDENCE: Witness, hotel records, photos, message documents and all kinds of related legal evidence. (Evidence to prove the allegation of adultery should be provided here.)
LEGAL REASONS: HMK, TMK and related legal legislation.
CONCLUSION and DEMAND: for the reasons described in detail above;
1-) DIVORCE of the parties due to adultery,
2-) Due to the fault of the defendant spouse, the plaintiff is paid … TL material, … TL non-pecuniary compensation,
3-) The custody of the joint children should be given to the client’s mother as a precautionary measure while the case is ongoing and definitively at the end of the case,
4-) Monthly payment to joint children ………..’er TL to pay alimony as a precautionary measure while the case is ongoing and to continue as a subsidiary alimony at the end of the case,
5-) We sincerely offer and request that the defendant decide to pay the trial costs and the power of attorney fee.
Deputy Plaintiff
Lawyer Name and Surname