……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Request for Reorganisation of Personal Relationship with the Child.
EXPLANATIONS :
1-My client and the defendant ended their 8-year marriage by mutual agreement. The applications of the parties ……. The applications of the parties were accepted by the Civil Court of First Instance, and the decision on divorce ……. date, ……. The decision dated ……. and numbered ……. has been notified to the parties and finalised.
2- In the decision, the joint child of the parties, Ayla, was given to the defendant mother. Since our client was working out of the city, she agreed to see the child only during the summer holidays and the court made the arrangement accordingly. Our client continues to regularly pay the alimony in the amount of ……., which the court has also appreciated.
3-Our client has completed his work outside the city and has started working again in the same city with the defendant and his child. She informed her ex-husband that she wanted to see her child every weekend according to this arrangement, without affecting her schooling, but received a refusal.
4-Child needs father’s love as well as mother’s love. It is our client’s most natural right to see her child regularly. The defendant prevents this.
5-We request your court to reorganise our client’s relationship with the child by taking into account the new situation of our client and to decide to see her child every weekend.
LEGAL GROUNDS : Civil Code and other legislation.
EVIDENCE : Divorce Decree, witnesses, Execution File, other evidence.
RESPONSE TIME : 10 days
CONCLUSION OF THE REQUEST : For the reasons explained, we request that the relationship between my client and her child be reorganised, that the defendant, who caused the lawsuit to be filed, be ordered to pay the costs, and that the opposing party’s attorney fee be awarded to us as an attorney in accordance with the 164/last paragraph of the Law No. 1136 on Attorneyship Law amended by Law No. 4667.
ATTORNEY FOR THE PLAINTIFF
……..
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