TO ANKARA FAMILY COURT ON DUTY
Plaintiff: Name-Surname (T.R. Identity Number)
Address
ATTORNEY: Atty. Name surname
Address
DEFENDANT: Name-Surname (T.R. Identity Number)
Address
SUBJECT: This is our petition for divorce, material and moral compensation, custody and alimony due to adultery.
DESCRIPTIONS:
(This part should be filled in articles, within the scope of the procedure specified by the Legislator, taking into account the content of the concrete case.)
1-) The parties were married on …/…/… and they have … joint children from this marriage. One of the joint children…. born and the other is …. He was born. The profession of the plaintiff is …… and his monthly income is … TL, the defendant is … and his monthly income is … TL.
2-) The marriage of the parties was shaken due to the defendant’s full fault, and the marriage became unbearable for the parties. He learned that the defendant had been cheating on the plaintiff client for months and was having an affair with someone else. (The events related to the alleged issue in this section should be explained with evidence.)
3-) The defendant’s deception of the plaintiff will be proven by the evidence presented to the court and to be collected.
For this reason, the parties’ divorce based on the reason for adultery, the custody of the joint children is given to the mother of the client as a precautionary measure and at the end of the case, while the case is ongoing, and the plaintiff client …. TL material, ……. It became necessary to file the relevant lawsuit in order to decide to pay ……….. TL per month to the joint children for non-pecuniary damage, as a precautionary measure, and at the end of the case, to continue as child support at the end of the lawsuit.
LEGAL EVIDENCE: Witness, hotel records, photographs, message documents and any relevant legal evidence. (The evidence to prove the allegation of adultery should be stated here.)
LEGAL REASONS: Code of civil procedure, Turkish civil law and relevant legislation.
CONCLUSION and DEMAND: For the reasons explained in detail above;
1-) DIVORCE of the parties due to adultery,
2-) Due to the fault of the defendant spouse, the plaintiff pays … TL material, … TL non-pecuniary damages,
3-) The custody of the joint children is given to the client mother as a precautionary measure and at the end of the case, while the case is continuing,
4-) Monthly ……….. TL for joint children to be paid alimony as a precautionary measure and at the end of the lawsuit, to continue as child support while the lawsuit is ongoing,
5-) We respectfully submit and demand that the trial expenses and attorney’s fees be paid by the defendant.
Plaintiff’s Attorney
Hunting. Name surname
