Petition for Divorce on Grounds of Adultery
[Enter Court Information] TO THE HONORABLE COURT
[Enter Location Information]
PLAINTIFF: [Enter Name]
ATTORNEY: [Enter Attorney Information]
DEFENDANT: [Enter Name]
SUBJECT: Divorce due to adultery.
STATEMENTS:
1-My client has been married to the defendant for 22 years. They have six children from their marriage. Their marriage records are located in [Province] Province, [District] District, [Neighborhood] Neighborhood, [Volume No.] Volume No., [Page No.] Page No., and [Registration Serial No.] Registration Serial No.
2-The defendant is a market vendor who occasionally travels outside the city to sell fruits and vegetables at markets and fairs. My client has been sewing at home for years and has been contributing to her husband’s livelihood and household expenses.
3-My client had been hearing rumors for a long time that her husband was cheating on her. The defendant, who had been coming home only on weekends for some time, told my client that his work was busy and that he sometimes had to sleep in his truck. When this situation continued for more than six months, my client began to suspect something and started following her husband. Observing that her husband regularly visited another house located in the [Enter region information] area at the address [Enter address information], my client discovered through her investigations that her husband was living with another woman as husband and wife.
4-
In this case, the defendant acted quite brazenly: he had his own name engraved on the doorbell and had a phone line installed in his name at the house, with subscriber number …………. Worse still, our client learned that the defendant had a son with this woman. When our client confronted the defendant about this situation, he did not deny it; on the contrary, he admitted it.
5- The defendant is not currently living with our client and the children. He is using the home at the address mentioned above with the other woman he is living with. The defendant’s infidelity has been proven both by his own statements, the statements of witnesses, and the child born from his extramarital relationship.
6- We request that the court grant our client a divorce from the defendant. Additionally, we request that the court order the payment of [Enter Amount] TL in spousal support, to be converted into alimony upon divorce, and [Enter Amount] TL in temporary child support for each child.
LEGAL BASIS:
Article 129 of the Turkish Civil Code and other relevant legal provisions.
EVIDENCE: Population registry records, witness statements, DNA tests, and all relevant medical reports and other evidence.
Response period: 10 days.
REQUESTED DECISION: Based on the stated grounds, we request that the parties be divorced on the grounds of adultery, that custody of the minor children be granted to the plaintiff, that the defendant pay the plaintiff monthly spousal support of [Enter Amount] TL and monthly [Enter Amount] TL in child support, the defendant to cover the litigation costs, and, pursuant to the final paragraph of Article 164 of the Lawyers’ Act No. 1136, as amended by Law No. 4667, that the opposing party’s attorney fees be paid to us, that is, to our attorneys.
PLAINTIFF’S ATTORNEY