TO THE JUDGESHIP OF THE … FAMILY COURT
PLAINTIFF :
TC IDENTIFICATION NUMBER :
ADDRESS :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT :
Address :
Subject: our petition includes divorce and alimony requests due to mental illness.
INSTRUCTIONS :
1 -) Our client married the wife of the defendant on the date of…/…/. As addition 1 shows from the family population record, the couple has two children from their marriage … and … in their names.addition 1. One of the children … is his age, and the other … is his age, and they are both small.
2 -) some time after the marriage of the couple, there were a number of changes in the habits and behavior of the defendant’s wife. So much so that the defendant’s wife began to exhibit behavior that became increasingly unstable, to experience serious difficulties in making decisions about anything, and to feel and experience that some things that did not actually happen actually happened. Meanwhile, the defendant also decried an intense forgetfulness that had never been seen before.
3 -) upon developments, the defendant’s wife, who underwent a serious health screening at the initiative of our client, was diagnosed. … Psychiatric hospital, Health Care Management edited by the report (Annex 2), as is evident from the name last illness, an incurable disease, medically accurate, but can be kept under control at a certain level. In the report mentioned, it is also clear that the defendant’s wife should be kept under observation for a certain period of time.
4 -) because of the situation in question, the couple’s common life has become increasingly unbearable. This negative situation in which the defendant partner falls, from time to time, even poses a serious danger in terms of common children who are still young. This last matter will be clarified by the statements of our witnesses whose names and addresses are written in the witness list (add 3), if your court deems it appropriate. However, both common children are still young and need maternal care and attention. For this reason, we demand that the joint children remain with our client for the duration of the case, and when it is decided that the couple will divorce, our client will be granted custody.
5 -) Our client is a housewife and does not have any income. Currently, he remains with his children, with his own parents. Because his parents ‘ economic situation is not good, he cannot get enough support from them. Both common children are still young and need maternal care and attention. For this reason, we demand that during the trial, total alimony for our client … TL, TL for each child … be decided, and that the joint children remain with our client for the duration of the trial.
6 -) for the reasons we have tried to explain above, it is necessary to open this case.
Legal reasons: 4721 P. K. m. 165, 168, 169, 175, 182, 4787 S. K. m. 4, 6100 S. K. m. 240, 266.
Legal evidence: family registration sample, photocopy of Identity Card, report dated, witness statements, expert review.
Results and Request: for the reasons we have tried to explain above, the parties joint divorce our client to stay with their children during the trial, the couple deciding to divorce in case of provision of custody our client our client for the joint monthly … … … TL TL TL month for each child and a total of liens in the amount of child support, alimony after divorce, poverty, and the child support as her continuation, we demand by proxy that the decision be made to load the trial costs and Attorney’s fees to the defendant. …/…/…
Addition 1. Family birth registration sample and photocopy of identity card,
…/…/… date …. Khatanesi’s … numbered report,
Names and addresses of witnesses and their subjects to testify
list of witnesses,
An example of an approved power of attorney containing one special authority.
Acting Plaintiff
