…. TO THE HONOURABLE JUDGE
…….
REQUESTING CEASE AND DESIST ORDER:…….
HIS ATTORNEY :…….
AGAINST PARTY :…….
SUBJECT : Notice request due to abandonment.
EXPLANATIONS :
1-Our client has been married to the other party for 15 years. Population records, ……. Province, ……. District, ……. Neighbourhood, Volume No; ……., Family No; ……., Sequence No; …….. They have four children named AYŞE, FATMA, SEYFİ and Sevgi from their marriage.
2- Our client is a housewife and the defendant works as a lorry driver and travels abroad. The other party stays abroad for 1 week to 10 days every time he goes abroad due to his job. Our client and her children are used to this situation. However, his wife has not returned home for 4 months since the last time he left and has not called either his wife or his children.
3-Our client learnt that his wife had rented another house in Izmir, bought furniture, had a telephone installed and even called his wife from this phone and invited her home. His wife stated that she would not return home again. And shouted at him. The other party has not fulfilled any of his responsibilities regarding the marriage for 4 months. Moreover he left his home without any justifiable reason.
4-Our client invites him to her home. Because she thinks about her marriage that has lasted for years and the future of her children.
5-The house we invited the other party to is the address of his own house, which he himself left 4 months ago. (………….. neighbourhood No: 15 Floor: 2 İzmit.) Our client is constantly at home. However a key was also left to ………………., which is the opposite neighbour at the same address. He can get the key from here at any time of the day.
6- Although the other party is the breadwinner of the house. We will also transfer the travelling expenses for his return home to him.
CONCLUSION OF THE REQUEST :
For the reasons explained, we request that the other party be notified to return to his home. And his wife within 1 month, otherwise, we request that a divorce case will be filed in accordance with Article 132 of the Civil Code.
WARNER’S REPRESENTATIVE
…….
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