TO THE ANKARA FAMILY COURT ON DUTY
PLAINTIFF: First and Last Name (T.C Identification Number)
Address
ATTORNEY: Av. Name-Surname
Address
DEFENDANT: First and Last Name (T.C Identification Number)
Address
SUBJECT: Divorce due to adultery, financial and moral compensation, custody and alimony is our petition for a lawsuit.
INSTRUCTIONS:
(This part should be filled out in accordance with the procedure specified by the Legislator in the case of articles, taking into account the content of the concrete event.)
1 -) The parties were married on the date of …/…/… and have joint children from these marriages. One of the joint children…. one is born and the other is …. he is born. The profession of the plaintiff is……… and the monthly income is… TL, and the defendant is………………. and the monthly income is… TL.
2 -) The marriage of the parties was shaken due to the defendant’s complete imperfection, the marriage became unbearable for the parties. The defendant found out that the plaintiff had been cheating on his client for months and that he was having an affair with someone else. (In this section, the events related to the alleged matter should be explained by giving evidence.)
3 -) It will be fixed with the evidence presented to the court that the defendant deceived the plaintiff and which will be collected.
For this reason, the divorce of the parties based on the cause of adultery, the custody of the joint children should be given to the client’s mother as a precaution while the case is ongoing and with certainty at the end of the case, the plaintiff should give the client …. TL material,……. TL monthly for joint children with moral compensation ………..’tl As the case continues, it has been necessary to open the relevant case so that it can be decided to pay alimony as alimony to continue as a precautionary measure and as a subsidiary alimony at the end of the case.
LEGAL EVIDENCE: Witness, hotel records, photographs, message documents and all kinds of relevant legal evidence. (Evidence to prove the allegation of adultery should be indicated here.)
LEGAL REASONS: HMK, TMK and related legal legislation.
CONCLUSION and DEMAND: for the reasons described in detail above;
1 -) DIVORCE of the parties due to adultery,
2-) The defendant must pay the plaintiff … TL material, … TL moral compensation due to the fault of the spouse,
3-) The custody of joint children should be given to the client mother as a precaution while the case is ongoing and with certainty at the end of the case,
4 -) Monthly for joint children……….. TL for both of them to pay alimony as a precautionary measure while the case is ongoing and to continue as a subsidiary alimony at the end of the case,
5 -) We sincerely supply and demand that the decision to pay the costs of the trial and the power of attorney fee be paid by the defendant.
Plaintiff’s Attorney
Attorney Name and Surname
