TO THE … FAMILY COURT
Plaintiff :
Attorney :
Defendant :
Address :
Subject : It consists of a request for a divorce decision due to very bad treatment.
Instructions :
1- The defendant and our plaintiff client …/…/…. then they got married. Population records, …province, …district, … neighborhood, … volume no, … family no, … next of kin. He has children from his marriages … and ….
2- The defendant has been coming home drunk almost every night since the last year and has been violent to both our client and his children. He also makes unspeakable curses and insults to his 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 his children had to take refuge in the neighbors. The intervening neighbors have warned the defendant several times, but the defendant has not corrected his actions and it has not been possible for the marriage union, which was decimated due to his own defective actions, to become obsolete again.
4- For the reasons described, it was necessary to open this divorce case.
Legal Reasons : 4721 p. Law m. 162 and other relevant legislation.
Legal Evidence : Population registration, witness statements and, if necessary, all kinds of legal evidence.
Conclusion and request : for the reasons described above, the parties to divorce, joint custody of their children to be given to the mother of the plaintiff, the plaintiff’s mother in the future to jointly measure for each child monthly …monthly …alimony to be converted into TL and TL from the defendant participate in the collection of alimony, litigation costs and attorneys ‘ fees by the defendant decided to bilvekale we will yukletilm regards to supply and demand.
Plaintiff’s Attorneys
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