TO THE COURT JUDICIARY
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : It is aimed at our request to remove from inheritance.
DESCRIPTIONS :
1-) Our client married his wife on …./…/… and the marriage union between the parties still continues. (ANNEX 1)
2-) The parties have been longing to have children since the first day of the marriage union, and in this direction, the plaintiff’s other spouse …./…./…. Due to the accident he had in history, he did not have the opportunity to have children medically. Our client and his wife, as a result of this sadness, with the advice of a family friend …./…./…. they adopted the defendant ….. (Annex – 2)
3-) The defendant became a source of happiness in the adopted family in a short time, and our clients treated the defendant as their own children and devoted all their assets to the defendant. However, the defendant started to borrow heavily after a while. So much so that, due to the debts incurred, the creditors identified our clients’ house and workplace and threatened them with death, and on …./…./… they shot the house where they lived. (Annex – 3)
4-) Our clients have repeatedly warned the defendant not to be in excessive debt, and even demanded that the adopted defendant keep an independent residence for a while due to a series of heinous events.
5-) Due to the reasons we have tried to explain above, it has become necessary to file this lawsuit in order to decide to remove the defendant from the inheritance due to the fact that the defendant acted largely in fault in fulfilling his family duties.
LEGAL REASONS: 4721 S. K. m. 500, 510
LEGAL EVIDENCE:
1-) Identity registration,
2-) Documents regarding the adoption proceedings.
3-) Police station and prosecutor’s office records
4-) Witness statements
CONCLUSION AND REQUEST: For the reasons we have explained above, we respectfully request on behalf of our client that the trial expenses and attorney’s fees be charged to the other party, and that the defendant’s adoption is decided to be removed from inheritance due to the fact that he acts largely in fault in fulfilling his family duties. …/ …/ …
Plaintiff’s Attorney
Hunting.
ATTACHMENTS:
1-) Identity registration,
2-) Documents regarding the adoption proceedings.
3-) Police station and prosecutor’s office records
4-) One copy of approved power of attorney
