ANTALYA SENTRY FAMILY COURT
AN INJUNCTION IS REQUESTED.
REQUESTING :A….. B….. (T.C.:…………….)
ADDRESS
ATTORNEY :Attorney…………………
ADDRESS
DEFENDANT :C….. E….. (T.C.:……………)
ADDRESS
CASE VALUE: 000.00 TL for now
SUBJECT OF CLAIM : It consists of a claim that he will receive a participation share arising from the liquidation of the goods regime.
OUR EXPLANATIONS
Client A….. B…. with the defendant C….. B…., October October 01, 2000, they were married (ANNEX-1) and have two children named X and Y (examples of population registration are attached ANNEX-2) from these marriages. October 1, 2000, they were married (ANNEX-1).
There have been problems between the defendant and the client that have started from time to time from the very beginning of marriages, all of which are caused by the defendant’s Decency, but these problems have become even more frequent in recent years.
As a result of the troubles experienced../../…. In the history of the Ankara ( ) Family Court….Dec… The divorce case has been substituted by us with the file numbered as-basis (ANNEX-3) due to the fundamental shaking of the marriage union; As of this date, the regime of participation in October acquired property between the parties has ended.
As a result of the trial, the Ankara ( ) Family Court …./… Base ../../…. History and …./… By Decree No. 4, the parties are divorced and this decision is October../../…. It has been finalized in its history.
The assets (October-5) that are known to us as the assets acquired by the defendant in the marital union are as follows:
1-………
Together with these, we also request from your Court that the defendant’s assets other than the client’s information and the accumulation in his bank accounts be determined by writing to the relevant places of the client and that all these items to be determined in the continuation of the trial be calculated during the liquidation.
That are described for all these reasons, the defendant doesn’t deal with the client side, and therefore, since the possibility exists of a sale from a client, with the determination of the first defendant in the marriage of the acquired assets, the receivables entity to identify your client to participate on this; as a result of these determinations, with the purpose of settlement of property of the defendant from the client since it is a sale, we request you to place liens on these goods.
LEGAL REASONS : HMK, TMK, TBK, Av. Blood. And other relevant legislation
EVIDENCE : Population records, Ankara … of the Family Court ../../…. History and …./… The main numbered file, ../../…. Date …./… Decree no., ../../…. Dated finalization decision, Land registry records, expert report, witness, discovery, oath and other delail.
We reserve the right to present evidence against the evidence presented/submitted by the counterparty
CONCLUSION AND CLAIM : For the reasons described above and which will be considered by your Honorable Court you’re
1-ACCEPTANCE of our just cause and all our demands,
2-Taking measures on immovable property submitted to the land registry,
3-Determination of the assets belonging to the defendant and the imposition of an injunction,
4-Liquidation of the goods regime in accordance with the provisions of the relevant article of the TCC,
5-Provided that our rights regarding the surplus to be determined as a result of the liquidation are reserved, we will receive TL 000.00 participation for now, with the legal interest to be processed from the date of the decision, taken from the defendant and given to the plaintiff,
6-We demand that all kinds of trial expenses and fees be determined by proxy to the other party for the assessment of the power of attorney.14.02.2022
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