… FAMILY COURT JUDGE
prosecutor :
T.C IDENTIFICATION NUMBER :
Address :
Attorney :
(
Legal representatives of the parties, if any)
address :
(
Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
Subject :
It is our petition that includes our requests for divorce, alimony and compensation for committing a crime.
CASE VALUE :
(
In cases related to property rights )
INSTRUCTIONS :
1-)
Our client was married to the defendant’s wife on his/her date. October October 1) As can be seen from the family population register presented in the appendix, the parties have children from these marriages … and … in their names. One of the children is … and the other is … years old, and both are small.
2-)
The defendant’s spouse is charged with the crime of sexual abuse of a child committed by the Criminal Court of Criminal Gravity /… E. As a result of the trial conducted on the numbered file, the said court …/… K. by his decision, in accordance with Article 103/2 of law 5237, he was sentenced to one year of hard labor imprisonment. Although the decision in question was appealed by the defense of the defendant spouse, it was finalized on the date of … /…/… passing the approval of the Supreme Court (APPENDIX 2).
3-)
The aforementioned conviction disgraced the defendant as well as our client before third parties, and our client was forced to leave his province where he lived with the defendant, together with his children, and settle next to his parents. Considering that the minor who was abused was a neighbor’s child, the situation is extremely bad for our client. October 3 October, this issue will be clarified by the statements of our witnesses, whose names and addresses are included in the witness list presented in the appendix, which they will give before your court.
3-)
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. Besides, since the defendant’s wife is already in prison, there is no one else to take care of the children. 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-)
In addition, for our client, who was forced to end his marriage for the reasons we are trying to explain and was dragged into a very difficult situation in front of the public, we are demanding a total compensation of TL, including TL material, TL moral.
LEGAL REASONS :
4721 Pp. K. m. 163, 168, 169, 174, 175, 182, 4787 P. K. m. 4, 6100 pp. K. m. 240, 266.
LEGAL EVIDENCE :
An example of a family population registration, a photocopy of a birth certificate, a confirmation annotation … .. /…/… history …/… E. …/…. K. court order, witness statements.
CONCLUSION AND PROMPT :
We have tried to explain the above reasons, our client to stay with their children during the divorce trial, the parties of the joint, 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 child support for her, as the continuation of our client in favor of TL financial…, … spiritual TL, TL recover total … , 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. …/…/…
ECLAIR :
1.
A sample of the family population registration and a photocopy of the identity card,2.
The final statement … .. /…/… history …/… E. …/…. K. court order,3.
It shows the names and addresses of the witnesses and the topics they will testify to witness list,
4. An example of a certified power of attorney, which includes one special authority.
Deputy Plaintiff
Lawyer