YOUR HONOR, THE SILIVRI FAMILY COURT
Plaintiff : A.B. (ID. No.: )
Deputy : Av.
Defendant : C.B. (TC: )
Subject : This is the presentation of our lawsuit petition, which includes our claims for divorce, custody, alimony, material and moral damages due to the fact that the defendant’s marriage union was shaken from its foundation due to his defective behavior.
Instructions :
Our Client A.B and defendant C.B. they married in 2010. From this marriage, D.B. they have a joint child named.
Since the beginning of the marriage, the defendant has been drinking alcohol every night and has been physically violent to our client. The defendant often commits this violence in front of the common child. Examples of the report of the october received by our client from the Silivri State Hospital and the testimony he gave at the Silivri District Police Department are presented in the appendix to our petition.
The defendant constantly humiliates, insults our client when he is alone and in public, and his appearance makes fun of business. With such behavior, our client is faced with verbal violence. These considerations will be proved by witness statements during the trial.
Finally, our client found out 1 month ago that the defendant was cheating on himself with a woman named X. While the defendant did not meet any of the needs of the joint residence, he rented a house to a woman named X and met all his needs. It is important to note that the defendant has a company of his own, and his monthly income is also quite high. In order to prove the defendant’s relationship with another woman, we request a subpoena from the relevant GSM operator of the caller, dialed and message records of the defendant’s phone number for 1 year retrospectively from the date of the lawsuit.
Although the defendant’s financial situation is very good, the joint child does not meet any needs of our client and the joint residence. Our client left his job in 2012 in order to take over the spiritual care of the joint child and has not been working since that date. Our client’s family pays for the purchases of the joint residence and the school needs of the joint child. The defendant does not fulfill any responsibility arising from the marriage union.
As can be seen from all this, due to the defendant’s defective behavior, our client is unlikely to continue the marriage. The marriage union has been shaken from its foundation and the common life has become unbearable for our client. For this reason, we request that the defendant and our client’s divorce be decided. Considering that the defendant is not interested in the common child, that the care of the common child is performed in the best way by our client and that the superior benefit of the child is taken into consideration, the common child D.B.we request that the temporary and final custody of the be granted to our plaintiff client. In addition, we request that a monthly alimony of 3,000.00 TL be decided for use in the care and benefit of the joint child, and that the alimony in question be decided to continue as a subsidiary alimony after the decision is finalized. We request that the defendant be fully defective, that the alimony of 3.000,00 TL per month be decided due to the fact that our client will fall into poverty due to the divorce, and that the alimony in question be decided to continue as a poverty alimony after the decision is finalized.
Due to the defendant’s defective behavior, our client has been both financially and spiritually worn out, and her pride in femininity has been repeatedly hurt. We request that the defendant be entitled to 200.000.00 TL financial compensation and 200.000.00 TL moral compensation for the reasons that the damages caused to our client are to be compensated a little, and the current and expected interests of our client are to be harmed.
Legal Reasons: TMK, HMK, etc. legislation.
Subtitle Evidence :
-Population records, land registry records, chamber of commerce records
-Social review report
-A report of a beating received by our client from the Silivri State Hospital and a sample of a statement given by him in the police
-Subpoena of the defendant’s phone number from the relevant GSM operator of 1-year caller, dialed and message records retrospectively from the date of the lawsuit
-Witness statements, Expert examination, etc. all the evidence.
Claim and Conclusion : As explained in detail above,
-Divorce of the parties,
-Granting custody of the joint child to our plaintiff client,
-Provision of alimony in the amount of 3,000.00 TL for use in the care and benefit of the joint child, the alimony in question will be continued as subsidiary alimony after the decision is finalized,
-The defendant is fully defective due to the fact that our client will fall into poverty due to the divorce, the monthly alimony of 3,000.00 TL will be decided, the alimony in question will continue as poverty alimony after the decision is finalized,
-Compensation of the damages caused to our client by the defendant to a certain extent, financial compensation of 200,000.00 TL and non-pecuniary compensation of 200,000.00 TL for the reasons of damage to the current and expected interests of our client,
-We sincerely ask and demand that the decision be made to burden the defendant with the costs of the trial and the attorney’s fee by proxy.
Deputy Plaintiff
You can read our other articles and petition examples by clicking here