Request For A Restraining Order Due To Alcohol Dependency
… TO THE JUDGE OF THE CIVIL COURT OF PEACE,
PETITIONER: TC No:
ADDRESS: :
ATTORNEY: :
ADDRESS: :
SUBJECT: This petition concerns the request for a restriction order due to alcohol addiction.
OUR EXPLANATIONS
1-) Our client currently resides at …… address, is married, and has … children.
2-) Due to the deterioration of his business as a result of the economic crisis, he has been in serious financial difficulty for the last … years. This ongoing economic hardship has gradually damaged family relationships and ultimately led to his spouse moving in with her family, taking their children with her.
3-) After being forced to close his business, our client had to sell his farm and shop to pay off his debts. However, the money obtained from the sale only covered part of his debts. Due to the problems he was experiencing, he gradually became addicted to alcohol, which he had only consumed for pleasure in better times, reaching the level of an alcoholic. The individuals listed in the witness list attached to our petition, whose names are included in the petition, will also provide explanations regarding the situation if deemed appropriate by your court. Meanwhile, he was fired from his job at the workplace located at … address, where he started working for minimum wage, on …/…/… due to alcohol. Since that date, unable to find work until today, he has started selling his household items to spot stores dealing in second-hand goods. It is evident that, as a result of this situation, he will eventually have no movable or immovable property left to sell.
4-) Our client is actually a skilled craftsman, an expert in his field. He is in danger of completely losing his family and his health. However, his alcohol addiction, which has now become a dependency, prevents him from thinking rationally, making sound decisions and acting on them, and thus turning his current adverse living conditions to his advantage.
5-) For the reasons stated and explained above, it has become necessary to decide on the restriction of our client and to appoint a guardian for him.
LEGAL GROUNDS: Turkish Civil Code No. 4721, Articles 21, 406, 409, 410, 414, 415
LEGAL EVIDENCE:
1-) Population records
2-) Witness statements
3-) Workplace records
CONCLUSION AND REQUEST: For the reasons explained above, due to alcohol addiction and the resulting negative consequences, we respectfully request that our client be restricted and that a guardian be appointed for him. …/ …/ …
ATTACHMENTS:
Attorney for the Petitioner