Sample Petition for Temporary Alimony
TO THE HONORABLE COURT
…….
PLAINTIFF:…….
ATTORNEY:…….
DEFENDANT:…….
SUBJECT: Alimony Request.
EXPLANATIONS: 1-Our client has been married to the defendant for 10 years. They have three children: one aged 9 and two aged 7 (twins). All three children attend elementary school.
2-For approximately 4 years, the defendant has been coming home late, sometimes spending the night away from home under the pretext of business trips. Although our client is disturbed by this situation, she has not spoken up until now due to the influence of her young children and her surroundings.
3-The defendant has completely abandoned the home for approximately 3 months. He is not involved with either our client or their young children. The home where our client and the defendant lived together was inherited by our client from her father. After getting married, our client quit her job as a secretary and became a housewife. She currently has no income. The defendant works in the insurance sector. His monthly income is approximately 4,000,000,000 TL (four billion TL).
4-Relatives and friends who intervened were unable to resolve the situation. Although the future of the marriage is uncertain, our client is not currently considering filing for divorce for the sake of her children’s future. However, she needs her husband’s help to support herself and care for her children.
5-We request provisional maintenance from the defendant in the amount of …… per month for our client and …… for each of our children, totaling ……
LEGAL BASIS:
MK.m.162 and other articles of law.
EVIDENCE: Population records, witnesses.
RESPONSE PERIOD: 10 days.
CONCLUSION: For the reasons stated, the Defendant is ordered to pay alimony in the amount of ……….. per month for our client and …… for each child, totaling …… Furthermore, as a precautionary measure during the trial, it has been decided that alimony shall be paid for the needs of our client and the children and that the trial costs shall be covered by the Defendant. We request that the opposing party’s attorney’s fees be awarded to us as representation in accordance with the last paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY
…….