…. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our request for divorce due to dishonour.
EXPLANATIONS :
1- Our client has been married to the defendant for 12 years. Population records……. Province, ……. District, ……. Mah. ……. Volume No, ……. Page No, ……. Registry Row No. The parties have 3 children from this marriage.
2- The defendant has been neglecting his home for a long time and does not fulfil the requirements of the marriage union. The defendant has been spending time with his friends who are not well known in his neighbourhood who are generally convicted of theft, drugs, etc.
3- This situation also negatively affects the life of our client and her family. Our client’s neighbours, who live in a small town, have broken off their neighbourly relations because of his wife’s friends.
4- The situation was explained to the defendant by his relatives. But the defendant was not interested. Together with his friends, they have been to the police station several times. Although he had no criminal record yet, even this situation was enough to wear out our client who was not used to this kind of family life.
5- We request the divorce of our client from the defendant who leads a dishonourable life.
LEGAL GROUNDS : Article 131 of the Civil Code and other legal legislation.
EVIDENCE : Population record, witness statements 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 the joint children be given to the plaintiff mother. The costs of the proceedings be charged to the defendant. And 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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