TO THE HONORABLE COURTPLAINTIFF :…….
ATTORNEY THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
THE ACCUSED: …….
SUTO THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
THE ACCUSED: …….
SUBJECT: A Request fory Due to Severe Maltreatment.
THE HONORABLE COURT
…….
PLAINTIFF :…….
ATTORNEY :…….
THE ACCUSED: …….
SUBJECT: A Request for Divorce and Alimony Due to Severe Maltreatment.
EXPLANATIONS:
1-Our client has been married to the defendant for 8 years. Their marriage took place in ……. Province, ……. District, ……. Neighborhood, ……. Volume Number, ……. Page No and …….. It is registered in the population registers with Registration number. The couple has three children named Elif, Semih and Sadiye.
2-The defendant became depressed due to being unemployed for the last two years. He comes home drunk almost every night and beats up both his wife, our client and his children. He is also swearing and insulting both our client and our client’s family.he defendant became depressed due to being unemployed for the last two years. Comes home drunk almost every night and beats up both his wife, our client and his c-The defendant became depressed due to being unemployed for the last two years. He comes home drunk almost every night and beats up both his wife, our client and his children. He is also swearing and insulting both our client and our client’s family.
3-Their neighbors, who lived in the same apartment, witnessed their frequent fights and our client had to take refuge with her neighbors many times with her children. The interveners warned the defendant repeatedly, but the defendant did not correct his behavior, and due to his own shortcomings, it was not possible to restore the marriage.
4-
The defendant’s continuing behavior shows that the benefits expected from this marriage can no longer be provided. We request that the court grant our client a divorce from the defendant.
5-The defendant’s lifestyle shows that he cannot take care of his children.-The defendant’s continuing behavior shows that the benefits expected from this marriage can no longer be provided. We request that the court grant our client a divorce from the defendant.
6-The defendant’s lifestyle shows4-The defendant’s continuing behavior shows that the benefits expected from this marriage can no longer be provided. We reque4-The defendant’s continuing behavior shows that the benefits expected from this marriage can no longer be provided. We request that the court grant our client a divorce from the defendant.
7-The defendant’s lifestyle shows that he cannot take care of his children. Therefore, we demand that the custody of the three children be granted to the plaintiff and that the defendant be ordered to pay monthly child support in total……. TL for the plaintiff and ……TL for each child ……TL.
LEGAL BASES: HUMK, MK and Related Legislation
EVIDENCE: Population Records, Witnesses, Forensic and All Kinds of Evidence.
RESPONSE TIME: 10 days
CONCLUSION: For the reasons stated above, we request that the parties be divorced, the custody of the children be given to the plaintiff, the plaintiff be paid a monthly precautionary alimony of …….-TL, which can be converted into poverty alimony in the future, the defendant be ordered to pay a monthly alimony of …….-TL for each child, the defendant be held responsible for the costs of the proceedings and the attorney fee of the other party be awarded to us in accordance with paragraph 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667.