FILED WITH THE ANKARA FAMILY COURT
Plaintiff: First Name, Last Name (Turkish ID Number)
Address
ATTORNEY: Attorney’s First Name, Last Name
Address
Defendant: First Name, Last Name (Turkish ID Number)
Address
SUBJECT: This is our petition for divorce on grounds of adultery, as well as claims for monetary and non-monetary damages, custody, and alimony.
EXPLANATIONS:
(This section must be completed in bullet points in accordance with the procedures established by the legislature and taking into account the specifics of the case.)
1-) The parties were married on …/…/… and have … children together from this marriage. One of the children was born at the age of ……, and the other was born at the age of …… The plaintiff’s occupation is …… and their monthly income is … TL; the defendant’s occupation is … and their monthly income is … TL.
2-) The parties’ marriage has been irreparably damaged due entirely to the defendant’s fault and has become intolerable for both parties. The plaintiff has learned that the defendant has been cheating on the plaintiff for months and is in 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 by the evidence to be submitted to and collected by the court.
Therefore, as a result of the parties’ divorce on the grounds of adultery, custody of the minor children has been granted to the plaintiff’s mother as a provisional measure and will remain with her upon the conclusion of the case; furthermore, a lawsuit must be filed to order the payment of …… TL per month as a provisional measure for non-pecuniary damages to the minor children due to the defendant’s material assets, and to continue as child support following the conclusion of the case. T L in material assets, and to order the payment of ……….. TL per month as a provisional measure for non-material damages to the minor children and, upon the conclusion of the case, as child support, it has become necessary to file the relevant lawsuit.
LEGAL EVIDENCE:
Witness statements, hotel records, photographs, message records, and all relevant legal evidence. (Evidence proving the allegation of adultery must be specified here.)
LEGAL GROUNDS: The Code of Civil Procedure, the Turkish Civil Code, and relevant legislation.
CONCLUSION AND REQUEST:
For the reasons detailed above;
1-) The parties shall be divorced on the grounds of adultery,
2-) Due to the defendant spouse’s fault, the defendant shall pay the plaintiff … TL in compensatory damages and … TL in moral damages.
3-) Custody of the minor children shall be granted to the plaintiff mother as a provisional measure and upon the conclusion of the case, while the case is ongoing.
4-) The monthly child support of ……….. TL, to be paid to the minor children as a provisional measure and upon the conclusion of the case, shall continue as child support for as long as the case is pending.
5-) We respectfully request that the defendant be ordered to pay the litigation costs and attorney’s fees.
Plaintiff’s Attorney
Last Name, First Name