Petition For Divorce On The Grounds Of Gross Misconduct
FAMILY COURT
Plaintiff :
Attorney :
Defendant :
Address :
Subject : It consists of a request for a divorce decision on the grounds of gross misconduct.
Explanations :
1- The defendant and our client were married on …/…/….. Their civil registry records are … province, … district, … neighborhood, … volume no, … family no, … row no.. They have children named … and … from their marriage.
2- The defendant has been coming home drunk almost every night since the last year and has been violent towards both our client and her children. He also uses unspeakable swear words and insults to our client and his children.
3- The fights were often witnessed by the neighbors of the parties living in the same apartment building, and several times our client and her children had to take refuge with the neighbors. The neighbors who intervened warned the defendant several times, but the defendant did not correct his actions and it was not possible to restore the marriage union that was disrupted due to his own defective actions.
4- For the reasons explained, it has become necessary to file this divorce case.
Legal Grounds : 4721 s. Law Article 162 and other relevant legislation.
Legal Evidence : Civil registry records, witness statements and all kinds of legal evidences when necessary.
Conclusion and Request : For the reasons explained above, we respectfully request and demand that the parties be divorced, that the custody of their joint children be given to the plaintiff mother, that the monthly …TL …for the plaintiff mother to be converted into poverty alimony in the future, and that the monthly …TL …for each joint child be collected from the defendant, and that the judicial expenses and attorney fees be imposed on the defendant.
Plaintiff
Deputies