… TO THE FAMILY COURT JUDGE
PLAINTIFF : TC No:
address :
attorney :
address :
DEFENDANT :
ADDRESS :
SUBJECT : The Payment of the Contribution Fee Includes Our Request to Be Paid, Consists of the Submission of Our Petition.
OUR EXPLANATIONS
1-) Our client married the defendant … … on the date of …/ …/ …. Their marriage, which went on smoothly at first, became unbearable due to the frequent fights, the violence of which gradually increased. Our client has filed for divorce with the lawsuit he filed on the date of … / …/… and … the Family Court has … / …/ … the date and … / … E. …/… K. with the numbered decision, it has been decided to divorce our client and the defendant. This decision has been finalized on the date of …/ …/ … without appeal.
2-) Our client is a graduate of … University and … has been nursing for a year. Our client continued to practice his profession even after the establishment of the marriage union on …/ …/… and the monthly average is … TL. he has earned income. Our client contributed to the receipt of the independent section numbered ada … located in the parcel, which was acquired during the period when he was married to the defendant and remained on the defendant’s side as a result of the divorce.
3-) 227 of the Turkish Civil Code No. 4721 entitled “Value Increase Share”. in the article;
“The goods of one person, the other person, to obtain protection or improvement or without suitable compensation has been contributed if this property during the liquidation resulting in the contribution shall have the right to take to increase the value, and this value is calculated according to the goods during the liquidation of that you will get a loss when it comes to value is based on the value of the initial contribution.” the arrangement is included.
4-) In accordance with the regulation contained in the legislation, … ada … in order to request from the defendant the contribution made by our client in the acquisition of the independent section numbered … in the parcel, it has become necessary to apply to your court.
LEGAL REASONS : 4721 P. K. m. 227, 228, 229, 230, 239, 240, 241 , 4787 P. K. m. 4.
LEGAL EVIDENCE : … Family Court …/ …/ … history and …/ … E. …/… K. it shows the numbered decision, Land Registry Records, the finalization annotation of the local court decision, the expert, the names and addresses of the witnesses and the topics to which they will testify, the witness list
Results and PROMPT : for the reasons we have explained above, …/ …/ … begins …/ …/ … in the history of marriage and divorce, which ended with a divorce in the Union as a result of the defendant acquired the parcel number in the name section … … the rest of the independent contribution to our client in exchange for the defendant is taken from TL to our client and provision, litigation costs and attorneys ‘ fees yukletilm the opposite side, to be determined with respect bilvekale on behalf of our client we require. …/ …/ …
ADDITIONAL :
Plaintiff Attorney
Lawyer.
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