Sample Petition For Change Of Custody
TO THE FAMILY COURT
THE PLAINTIFF
Name, Surname, Turkish ID Number and Address
ATTORNEY
Av. MEHMET AŞIKOĞLU
Address Hacet Mah. Canlılar sk. Lawyers business center No: 7
Interior Door No: 2 Alanya/ANTALYA
DEFENDANT
Name, Surname and Address
VICE PRESIDENT:
(You fill in here)
SUBJECT:
It is about our request for change of custody.
EXPLANATIONS:
1-The client and the defendant divorced with the decision of Kahramanmaraş Family Court dated … and numbered 2012/… E. and 2012/… K.; the custody of the joint child …………. was given to the defendant.
2-After the divorce, the father, to whom the custody was given after the divorce, had behaviors in the form of ………………………………. that would prevent the child’s physical, intellectual and moral development.
3-On the other hand, the client has started to work and has established a home where she and the child can live comfortably. She has become prosperous enough to take on the expenses of the child.
LEGAL GROUNDS
TMK Art. 335-351, HMK and Related Legislation
LEGAL EVIDENCE
Witness statement, oath and any legal evidence.
REQUEST AND CONCLUSION:
For the reasons presented and explained above, to take the custody of the joint child ………. from the father and give it to the client, to remove the alimony paid by the client and the defendant …….. TL, to establish a personal relationship between the father and the joint child, and to charge the defendant with the costs of the proceedings and attorney’s fees. …./…../…..
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