ANKARA FAMILY COURT DUTY JUDGE
Plaintiff: Name-Surname (TC ID No.)
Address
ATTORNEY: Attorney Name-Surname
Address
DEFENDANT: Name-Surname (TC ID No.)
Address
SUBJECT: Our case is for divorce due to adultery,. Material and moral damages, custody, and alimony.
EXPLANATIONS:
(This section should be filled out in accordance with the procedure determined by the Legislator, taking into account the content of the specific case.)
1-) The parties married on …/…/…, and they have … children from this marriage. One of the children was born on … and the other was born on …. The plaintiff’s profession is … and their monthly income is … TL, while the defendant’s profession is … and their monthly income is … TL.
2-) The marriage of the parties has been shaken due to the defendant’s full fault and has become unbearable for the parties. The plaintiff’s client has learned that the defendant has been cheating on them for months and has a relationship with another person. (The events related to the alleged issue in this section must be explained with evidence.)
3-) The defendant’s infidelity will be proven. With evidence to be presented and collected by the court.
Therefore, in the divorce based on adultery, custody of the children has been provisionally granted to the plaintiff’s mother, and the plaintiff is entitled to monthly alimony of … TL during the proceedings. The court has awarded TL in material damages, and …….. has been ordered to pay monthly ……….. TL in moral damages to the joint children. In order for a decision to be made on the payment of alimony at the end of the case as a precautionary measure, it is necessary to file the relevant lawsuit.
LEGAL EVIDENCE: Witnesses, hotel records, photographs, message documents, and all relevant legal evidence. (Evidence proving the allegation of adultery should be specified here.)
LEGAL GROUNDS: HMK, TMK, and relevant legislation.
CONCLUSION AND REQUEST: For the reasons detailed above;
1-) The parties shall be DIVORCED due to adultery.
2-) The defendant spouse shall pay the plaintiff … TL in material damages and … TL in moral damages due to his fault.
3-) Custody of the children shall be granted to the client mother as a precautionary measure and at the end of the case while the case is ongoing.
4-) Monthly alimony of ……….. TL shall be paid for the joint children as a precautionary measure and shall continue as alimony for the duration of the lawsuit until its conclusion,
5-) We respectfully request that the defendant pay the court costs and attorney’s fees.
Plaintiff’s Attorney