Motion to Submit Evidence in a Contested Divorce Case

Motion to Submit Evidence in a Contested Divorce Case

ANTALYA ……..FAMILY COURT

CASE NO: ……….. E.

EXPLANATION

DEFENDANT: ………..

ATTORNEY: Attorney……………

PLAINTIFF: …………….

ATTORNEYS: Attorney…………….

SUBJECT: Our explanations regarding the minutes of the hearing dated 19.04.2022.

EXPLANATIONS:

Your Honor, with the minutes of the hearing dated 19.04.2022, you have informed us that << .. “The parties shall submit the documents they have mentioned in their petitions but have not yet submitted to the court within a strict two-week period or shall make the necessary statements to obtain the documents to be submitted from another location (address, branch, unit, or center where the document will be requested, etc.), otherwise they shall be deemed to have waived their right to rely on this evidence.” It was noted that the notification of this approval record and the invitation to the preliminary examination hearing constituted notification of the warning. In accordance with the hearing record, we submit our statements and explanations to Your Honorable Court, reserving our right to present evidence against the opposing party’s evidence.

Evidence:

1- Family Population Registration Example (To be added to the file with our petition.)

2- Investigation of the social and economic circumstances of the parties,

A) Bank records and receipts (Please send a letter requesting information to the relevant institutions)

3- Land registry records

4- Inquiry into the real estate and vehicle registrations belonging to the plaintiff ………..(TC NO: …………….) (It is requested that this be queried through the UYAP system)

5- Issuing an instruction to the Afyonkarahisar Duty Family Court to prepare a social investigation report on ………………. and …………………..

7- Social Security Institution (SGK) records (request to be obtained from the SGK institution)

8- Writing a memorandum to the Child Protection Agency requesting the relevant records be obtained

9- Telephone records (requesting that minutes be taken at the relevant locations)

10- Messaging records (requesting that minutes be taken at the relevant locations)

11-Investigation

12-Expert examination

13-Oath

14-All other legal evidence

CONCLUSION AND REQUEST: In accordance with the interim decision dated 19.04.2022, we respectfully submit our statements to the Honorable Court. 05.05.2022

DEFENDANT’S ATTORNEY

Attorney…………….

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