…TO THE FAMILY COURT JUDGE;
Prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : This is our petition, which includes our requests for divorce and child support due to mental illness.
INSTRUCTIONS :
1-) Our client married the defendant’s wife on /…/… date. As october be understood from the family population register presented in the annex to our petition (OCTOBER 1), the couple has two children from these marriages and … in their names. One of the children is … years old, and the other is … years old, and both are small.
2-) Some time after the couple’s marriage, there have been some changes in the behavior and behavior of the defendant spouse. So much so that the defendant spouse began to exhibit increasingly unstable behavior, have serious difficulties in making decisions about anything, and feel and experience some things that really didn’t happen as if they had really happened. Meanwhile, an intense forgetfulness that had never been seen before also occurred in the decedent spouse.
3-) According to the developments, the defendant spouse, who underwent a serious medical examination at the initiative of our client, was diagnosed with … … Psychiatric hospital, Health Care Management edited by the report (Annex 2), as is evident from the name last illness, an incurable disease, medically accurate, but can be kept under control at a certain level. It is also clearly stated in the mentioned report that the defendant spouse should be kept under observation for a certain period of time.
4-) Due to the situation in question, the joint life of the couple has become increasingly unbearable. This negative situation, into which the defendant spouse falls, even poses a serious danger from time to time in terms of common children who are still young. This last point will be clarified by the statements that our witnesses, whose names and addresses are written in the witness list (ANNEX 3), will give in relation to the matter, if your court deems it appropriate. Moreover, both of the joint children are still young and need maternal care and attention. Therefore, we request that the joint children remain with our client for the duration of the case, and that custody be given to our client when it is decided that the couple will be divorced.
5-) Our client is a housewife and does not have any income. Currently, she, along with her children, is staying with her own parents. Because her parents’ economic situation is not good, she cannot get enough support from them. Both of the joint children are still young and need maternal care and attention. Therefore, we request that a total of alimony of TL be decided for our client during the trial, TL for each child, TL for each child, and that the joint children be decided to stay with our client during the trial.
6-) For the reasons that we have tried to explain above, the obligation to open this case has arisen.
LEGAL REASONS : 4721 P. K. m. 165, 168, 169, 175, 182, 4787 P. K. m. 4, 6100 pp. K. m. 240, 266.
LEGAL EVIDENCE : Sample family population registration, photocopy of identity card, …/…/… dated report, witness statements, expert examination.
Results and PROMPT : for the reasons we have tried to explain above, the parties joint divorce our client to stay with their children during the trial, the couple deciding to divorce in case of provision of custody our client our client for the joint monthly … … … TL TL TL month for each child and a total of liens in the amount of child support, alimony after divorce, poverty, and the child support as her continuation, we request by proxy that it be decided that the costs of the trial and the attorney’s fee will be charged to the defendant. …/…/…
APPENDIX 1. OCTOBER 2010. A sample of the family population registration and a photocopy of the identity card,
…/…/… date …. Report of Hatanesi … no.,
The names and addresses of the witnesses and the topics they will testify to
shows witness list,
An example of a certified power of attorney, which includes one special authority.
Deputy Plaintiff
Lawyer