……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Divorce and Alimony Request due to Unfavourable Treatment.
EXPLANATIONS :
1-Our client has been married to the defendant for 8 years. Marriage population records……. Province, ……. District, ……. Neighbourhood, …….Skin No, ……. Page No and……. Registry Row Number. They have three children named Elif, Semih and Sadiye.
2- The defendant has been depressed due to being unemployed for the last two years. Almost every night he comes home drunk and beats both his wife, our client, and his children. He also swears and insults both our client and our client’s family.
3- Most of the time, the neighbours living in the same apartment building witnessed their fights and several times our client had to take refuge with her children with her neighbours. The neighbours warned the defendant several times. The defendant did not correct his behaviour and it was not possible to restore the marriage union, which was disrupted due to his own defective behaviour.
4- The ongoing behaviour of the plaintiff shows that the expected benefit of this marriage can no longer be achieved. We request that our client be granted a divorce from the defendant.
5-The defendant’s living arrangement reveals that he cannot take care of his children. For this reason, we request that the custody of the three children be given to the plaintiff, and that the defendant be ordered to pay a monthly alimony of …….TL for the plaintiff and …….TL for each child, totalling …….TL per month.
LEGAL GROUNDS : HUMK, CC. and Related Legislation
EVIDENCE : Population Register, Witnesses, legal and all kinds of evidence.
RESPONSE TIME : 10 days
CONCLUSION OF THE REQUEST :
For the reasons explained, we request that the parties be divorced, the custody of their joint children be given to the plaintiff, the monthly …….-TL precautionary alimony for the plaintiff mother to be converted into poverty alimony in the future and the monthly …….-TL participation alimony for each joint child be collected from the defendant, the costs of the proceedings be charged to the defendant, and in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667, we request that the counterparty attorney fee be awarded on our behalf as an attorney.
ATTORNEY FOR THE PLAINTIFF
…….
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