To the Honorable Judge
COMPLAINANT:
ATTORNEY:
DEFENDANT:
CRIME: FAILURE TO COMPLY WITH CHILD CUSTODY
EXPLANATIONS: Our client and the defendant divorced on ……. at the ……. First Degree Court ……. Main and ……, with decision number …….
2- During their marriage, their child was given to the defendant mother, namely … years old … The court ruled that the minor… Should be seen by his father every Saturday between 11:00 a.m. and 4:30 p.m.
3- Our client wanted to settle this matter amicably without involving bailiffs, but the defendant did not agree. Upon this, a decision was made by the …… Enforcement Directorate on ../../…. This decision was enforced under file number E, and 55 Enforcement Orders were served on the defendant, completing the process.
4- The defendant persists in not complying with the court’s decision. Although our client went to pick up the child with an officer for three weekends, the defendant abducted the child on the grounds that he was taking him to the doctor. Despite being warned in the enforcement file, the doctor has not submitted his report.
5- The defendant’s IİK. We request that the crime be punished in accordance with Articles 25/a and 341.
LEGAL GROUNDS: IİK. Articles 25/a and 341
EVIDENCE: Application File, witnesses
RESULT OF THE REQUEST: For the reasons stated, we request that the defendant be punished, that the trial costs be borne by the defendant, and that the other party’s attorney’s fees be determined on our behalf in our capacity as attorneys, in accordance with the last paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Act No. 4667.
ATTORNEY OF THE COMPLAINANT