
……. TO THE HONOURABLE JUDGE
…….
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : The monthly maintenance of ……………….. ……. ……. per month with the increase of ……..
EXPLANATIONS :1- Defendant ……. and our client ……. ……. date of the Civil Court of First Instance, ……. E. and ……. They divorced with the decree numbered K.
2-As a result of the divorce, the custody of ……., born ……., the joint child of the spouses, was left to his mother. No alimony was provided for the joint child in this judgement. However, as a result of the increase in the child’s expenses and school expenses in the face of aggravating living conditions, our client ……. for the alimony of the joint child ……. In the Civil Court of First Instance ……. E. filed a lawsuit with the file numbered.
3- ……. Civil Court of First Instance ……. date, ……. E. and ……. K., …….-TL per month for the joint child ……. was ruled as maintenance for the joint child ……..
4- The monthly maintenance of …….-TL ……., which was ruled in ……., has become insufficient as a result of the economic conditions of the day and the growth and needs of the joint child. The joint child Necdet Onur is currently studying in the sixth grade of Anatolian High School.
5- Considering the improvement in the economic situation of the defendant, the decrease in the purchasing power of money against high inflation and the increase in the needs of the joint child, it has become necessary to file this lawsuit.
LEGAL GROUNDS : Code of Civil Procedure, Civil Code and Related Legislation
EVIDENCE :
….. 1 AHM File No. ../… E.
….. 2 AHM File No. ../… E.
Financial and Economic Situation Survey of the Parties
Population Records, Witnesses, Legal and Other Discretionary
CONCLUSION OF THE REQUEST : For the reasons stated above, we request that the monthly alimony of the subsidiary alimony of ……. be increased to ……. per month with an increase of ……. per month, that the defendant be charged with the costs of the proceedings, and that the counterparty attorney fee be awarded on our behalf as an attorney 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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