……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : It consists of a request for precautionary alimony.
EXPLANATIONS :
1-Our client is the defendant’s wife of 10 years. She has 3 children from their marriage, one of whom is 9 and the other two are 7 (twins). All three children are in primary education.
2-The defendant has been coming home late and staying out from time to time, using business trips as an excuse for about 4 years. Although our client is disturbed by the situation, she has not raised her voice until today with the influence of her young children and her environment.
3-For about 3 months, the defendant has left the house completely. The house where our client and the defendant live jointly was inherited by our client from her father. After her marriage, our client left her job as a secretary and became a housewife. She does not have any income at the moment. The defendant is an insurance broker. His income is around 4.000.000.000.000.-TL (Four billion TL) per month.
4- Relatives and friends who intervened could not improve the current situation. Although the future of the marriage is unknown, our client does not intend to file for divorce for the future of the children. However, she needs the help of her husband for her own livelihood and the care of the children.
5- We demand from the defendant a monthly alimony of ……. for our client and ……. for each child, totalling ……..
LEGAL GROUNDS : Article 162 of the Civil Code and other articles of law.
EVIDENCE : Population records, witnesses
RESPONSE TIME : 10 Days
CONCLUSION OF THE REQUEST :
For the reasons explained, we request that the defendant be ordered to pay ……….. per month for our client and ……. per month for each child, and a total of ……. as a precautionary measure for the needs of our client and her children during the continuation of the lawsuit, to charge the defendant with the costs of the proceedings, and to award the opposing party’s attorney fee 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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