TO THE HONORABLE JUDGE
Complainant :…….
Attorney:…….
The defendant :…….
OFFENCE: FAILURE TO COMPLY WITH CHILD SUBMISSION
Explanations: our client and the defendant ……. history ……. The Court Of First Instance Of ……. Mainly and……. They were divorced by decree.
2-joint children in their marriage .. old ….. it was given to the defendant’s mother. Court small….. he decried his father’s visit every weekend between 11.00 am and 16:30 am on Saturday.
3-Our client wanted to settle this meeting through an agreement without engaging the bailiffs, but the defendant did not agree to it. On top of that, the announcement was made by our client ../../…. in the history …… of the Executive Directorate ../…. Base. He put it into execution with his numbered file and the defendant was notified of 55 examples of the execution order in this regard.
4-the accused resists not complying with the ilam provision despite this. Our client went to pick up the child with the officer on 3 weekends, but the defendant kidnapped the child on the grounds that he had taken the child to the doctor. Although he was cautioned in the execution file, he did not submit a doctor’s report.
5-the first of the accused. According to Articles 25/A and 341, we ask that the act that constitutes a crime be punished.
LEGAL REASONS: IIK. Articles 25 / A and 341
Evidence : execution file, witnesses
Conclusion of the claim : We demand that the accused be punished for the reasons described, that the costs of the trial be charged to the accused and that the counterparty’s attorney fee be decided on our behalf as a lawyer in accordance with the last paragraph 164/of the Law No. 4667 of the Law No. 1136.
ATTORNEY COMPLAINANT
