OFFICE OF THE PUBLIC PROSECUTOR
COMPLAINANT: First Name, Last Name, Turkish ID No.
Address:
Members of Parliament:
Address:
SUSPECT: First Name, Last Name, Turkish ID No.
Address:
CRIME: Violation of the Enforcement Order Regarding the Handover of Children
DATE OF OFFENSE:
INSTRUCTIONS
1-Our client and the suspect were divorced pursuant to the decision of the. Family Court dated… and numbered… /… E. In the context of this divorce, it was decided that joint custody of the children would be left to the discretion of the court and that a personal relationship between the child and the parent would be established every weekend.
2-Although our client attempted to arrange this visitation through mutual agreement rather than through compulsory enforcement, the defendant refused to comply with the condition of appearing.
3-Furthermore, on behalf of our client, on…/…/…, the. Enforcement Directorate carried out the enforcement proceedings under Case No. …/….. E., and the Enforcement Order regarding this matter was served on the defendant and finalized.
4- By failing to be present at the residence or by refusing to hand over the child, thereby obstructing the service of the notice, the suspect has committed the offense of “resisting a child custody order,” and a criminal complaint must be filed to ensure separate punishment for each instance.
LEGAL EVIDENCE: Court decision, enforcement case file, and all other legal evidence.
LEGAL GROUNDS: Enforcement and Bankruptcy Law and relevant legislation.
CONCLUSION AND RECOMMENDATION
For the reasons outlined above, we earnestly and knowingly request that a public prosecution be initiated to punish the suspect for committing the offense of “refusal to comply with a child custody order” as specified in Article … of the Enforcement and Bankruptcy Law.
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