TO 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, alimony and compensation claims due to criminal action.
LITIGATION VALUE :
(In cases related to property rights )
INSTRUCTIONS :
1-)
Our client is married to the defendant’s wife. As Addition shows from the family population record, the parties have children from these marriages … and … in their names. One of the children … and the other … is his age, and they are both small.
2-)
The defendant’s wife, for the crime of sexual abuse of a child that was thrown at her, was found in the Criminal Court … / … E. As a result of the trial on the numbered file, the said court …/… K. by his decision, in accordance with article 103/2 of law 5237, he was sentenced to a heavy imprisontment sentence of many years. Although the decision in question was appealed in defense of the defendant’s wife, it was finalized on the date of the Supreme Court’s approval (October 2) .
3-)
The conviction disgraced the defendant as well as our client in front of third parties, and our client was forced to leave the province where he lived with his children with the defendant and settle with his parents. Considering that the abused minor is a neighbor’s child, the situation is extremely bad for our client. Addition 3 : this matter will be clarified by the testimony of our witnesses, whose names and addresses are included in the witness list presented in the Annex, before your court.
3-)
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. Besides, since the defendant’s wife is already in prison, there is no one else to take care of the children. 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-)
In addition, for our client, who was forced to terminate his marriage for the reasons we are trying to explain and was dragged into a very difficult situation in front of the public, we demand a total compensation of… TL, …TL material, …TL immaterial.
LEGAL REASONS :
4721 S. K. m. 163, 168, 169, 174, 175, 182, 4787 S. K. m. 4, 6100 S. K. m. 240, 266.
LEGAL EVIDENCE :
Example of family registration, photocopy of identity card, comment on completion … .. History of the Criminal Court …/…/… B. …/…. D. court order, witness statements.
CONCLUSION AND PROMPT :
We have tried to explain the above reasons, our client to stay with their children during the divorce trial, the parties of the joint, 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 child support for her, as the continuation of our client in favor of TL financial…, … immaterial TL, TL recover total … , we demand by proxy that the decision be made to load the trial costs and Attorney’s fees to the defendant. …/…/…
ECLAIR :
1.
Family birth registration sample and photocopy of identity card, 2.
Finalization statement .. History of the Criminal Court …/…/… B. …/…. D. court order,3.
A witness list that shows the names and addresses of witnesses and the topics they will testify to,
4. An example of an approved power of attorney containing one special authority.
Acting Plaintiff
