……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : Our Request for the Prohibition of the Defendants’ Marriage.
EXPLANATIONS :1-We request that ……., one of the defendants, who recently divorced our client, be barred from marrying the other defendant ……..
2-Defendants ……. and my client ……. were divorced with the decision of the Civil Court of First Instance dated ……. and numbered …….. The divorce decision was notified to the parties and finalised since it was not appealed.
3- The defendant is married to our client and during the divorce proceedings, she told her mutual friends that she was pregnant. Since the tension of the divorce with our client was in question, he did not mention this issue to our client.
4-Since the divorce was uncontested, it was finalised in a very short time. Our client later learnt that his ex-wife was pregnant. We have now learnt that the defendant is about to get married.
5-The marriage of the defendant in this situation may cause the birth of the child to be confused. We request that the defendant, who is pregnant with a child of our client, be prohibited from marrying during the period of iddat.
LEGAL GROUNDS : Article 93 et seq.,103,104 of the Civil Code.
EVIDENCE : Population records, divorce file.
TIME FOR ANSWER : 10 days
CONCLUSION OF THE REQUEST : For the reasons explained, we request that the marriage between the defendants be prohibited, that a preliminary injunction be issued in order to prevent the marriage contract until the end of the trial, taking into account the pregnancy of the former wife of our client from the defendants, that the costs of the trial be charged to the defendant, and that the counterparty attorney 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.
ATTORNEY FOR THE PLAINTIFF
…….
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