… TO THE FAMILY COURT JUDGE
IDENTIFICATION NUMBER :
ADDRESS :
ATTORNEY:
(
Legal representatives of the parties, if any)
ADDRESS :
(
Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT :
It is our petition that includes our requests for divorce, alimony and compensation due to committing a crime.
CASE VALUE:
(
In cases related to property rights)
DESCRIPTIONS :
one-)
Our client married the defendant’s wife on …/…/…. As it can be understood from the family identity record presented in Annex (Annex 1), the parties have children named … and … from these marriages. One of the children is … and the other is … years old, and both are young.
2nd-)
Defendant spouse, due to the crime of sexual abuse of the child who was thrown at him, as a result of the trial conducted on the file numbered …/… E. of the … Heavy Penal Court, with the decision of the aforementioned court numbered …/… K., in accordance with article 103/2 of the law numbered 5237. He was sentenced to … years of heavy imprisonment. Although the said decision was appealed by the defense of the defendant spouse, it was finalized on …/…/… after the approval of the Supreme Court (Annex 2).
3-)
The aforementioned conviction disgraced our client, as well as the defendant, in the eyes of third parties, and our client had to leave the province where he was living with the defendant, together with his children, and settle down with his parents. Considering that the abused minor is the neighbor’s child, the situation becomes extremely bad for our client. This matter will be clarified by the statements of our witnesses, whose names and addresses are included in the attached witness list (Annex 3), to be given before your court.
3-)
Our client is a housewife and does not have any income. Currently, she stays with her own parents with her children. She cannot get enough support from her parents because their economic situation is not good. Both of the joint children are still young and in need of mother’s care and attention. Moreover, since the defendant spouse is already in prison, there is no one else to look after the children. For this reason, we demand that during the lawsuit, a total of … TL of alimony, which is … TL for our client and … TL for each child, and that the joint children stay with our client throughout the trial.
6-)
In addition, for our client, who had to end his marriage due to the reasons we tried to explain and was dragged into a very difficult situation in front of the public, we demand a total of … TL compensation, including … TL material and … TL moral.
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:
Copy of family identity record, copy of identity card, with annotation of finalization … .. High Criminal Court …/…/… date …/… E. …/…. K. court order, witness statements.
RESULT AND REQUEST:
For the reasons we have tried to explain above, the divorce of the parties, the joint children staying with our client during the trial, the custody of the couple to be given to our client in case of divorce, the maintenance allowance of … TL per month for our client and … TL per month for each of the joint children, We request by proxy that this alimony be continuation as poverty and participation alimony after the divorce, to be decided in favor of our client, for a total compensation of … TL of … TL material and … TL moral, and the court expenses and attorney’s fee to be charged to the defendant. …/…/…
ATTACHMENTS:
one.
Copy of family identity record and ID card, 2.
With annotation of finalization … .. High Criminal Court …/…/… date …/… E. …/…. K. court order, 3.
The witness list showing the names and addresses of the witnesses and the subjects they will testify,
4. A copy of a certified power of attorney containing one special authorization.
