ANTALYA SENTRY FAMILY COURT
REQUESTING :A….. B….. (ID.:…………….)
ADDRESS
ATTORNEY :Attorney……………
ADDRESS
DEFENDANT :C….. E….. (T.C.:……………)
ADDRESS
SUBJECT OF REQUEST : The case consists of the submission of our petition.
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.
Defendant Yan has constantly caused problems for no reason during his marriages and has shown disrespectful, unloving and disinterested attitudes towards both the plaintiff client and his family. After every fight that was taken out for nothing, he left the communal residence, leaving his children behind; each time he wanted to return home, denying his claims. The client has made great efforts to maintain this marriage until this time.
Since the beginning of their marriage, the defendant has been disrespectful, unloving and disinterested towards his wife, children and his wife’s family, and has constantly left his home, leaving behind his children, mostly young children, in a way that has shaken the relationship of trust.
Finally../../…. The defendant, who had started a fight for reasons out of nothing in his history, left the house again and a month passed after this abandonment. During this process, the defendant, who did not return home, constantly caused problems for various reasons and refused to return to his home and children.
Upon application by us, the Ankara … Family Court ../../…. History and …./… A warning decision (October-3) has been issued regarding the defendant’s return home with the numbered main file; this decision../../…. It has been communicated to him in October (ANNEX-4).
Despite this warning, which has been notified, the necessity of opening this case has been determined by us, as it is not possible to continue the marriage union between the defendant and the client, who did not return to the common residence without a Dec reason, since it is impossible.
However, the client has a fixed residence permit (October-5), and it will be in their interests to stay with the plaintiff client, given the age of the children, the schools they attend, and the lifestyle they are used to. Because the defendant party does not have a fixed residence, and it is not even clear where he will reside yet. In addition, it is clear that at the point of repeated disloyal acts by the defendant and unrelated to both him and his children, the joint children will have a healthier life process with the plaintiff client, their education will not be disrupted, and they will find a happy and warm family environment.
For this reason, we request that the custody of the minor children who are with the plaintiff client be given to the plaintiff client during this process and that a temporary custody relationship be established in favor of the plaintiff client during the lawsuit process.
LEGAL REASONS : HMK, TMK, Av. Blood. And other relevant legislation
EVIDENCE : Population records, settlement documents, Ankara … of the Family Court ../../…. History and …./… The main numbered file, ../../…. Dated notification envelope, 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-DIVORCE of the parties due to abandonment,
3-Granting custody of joint children of younger age to the plaintiff client and granting temporary custody in favor of the plaintiff client during the litigation process,
4-Alimony for the return of joint children should be decided monthly by a reasoned decision during the trial period and after the trial in favor of each of them, and this price should be increased by the State Statistical Institute or the relevant institution at the rate of increase in the Producer Price Index determined by the relevant institution in the coming years,
5-We demand that all kinds of trial expenses and fees be decided by proxy to the other party for the assessment of the power of attorney.11.02.2022
Deputy Plaintiff
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