… TO THE JUDGE OF THE FAMILY COURT
PLAINTIFF:
TURKISH REPRESENTATIVE NUMBER:
ADDRESS:
REPRESENTATIVE:
ADDRESS:
DEFENDANT:
ADDRESS:
SUBJECT: Our Petition Requesting a Separation Decree.
EXPLANATIONS:
1-) Our client, … …, and the defendant, … …, were married on …/…/…. Our client and the defendant, who met during their university years before their …-year marriage, decided to unite their progressing relationship through marriage.
2-) The defendant, … …, is a merchant and works in the … business. The defendant went bankrupt on …/…/… and, due to the economic difficulties he is experiencing, turned to alcohol, became dangerously alcoholic, neglected his responsibilities as a spouse, and made the marriage unbearable. The number and intensity of arguments between the husband and wife have increased day by day. We have witnesses available to testify in court regarding this matter.
3) Our client’s love for his wife has not diminished at all, and he remains extremely faithful to her as his life partner. Although the financial difficulties have not reached a point where they would dissolve the marriage, our client wishes to save his marriage by temporarily separating from his wife, giving both himself and his wife time.
4) In order to facilitate a smoother transition through this difficult and stressful period for both parties and to prevent the marriage from ending in the unfortunate institution of divorce, it has become necessary to apply to your court on behalf of our client for a separation decree.
LEGAL GROUNDS: Articles 167, 169, 170, 171, 172 of Law No. 4721
LEGAL EVIDENCE:
1) Population registry record showing the marital union between the parties.
2) Witness list showing the names and addresses of the witnesses and the subjects they will testify about.
CONCLUSION AND REQUEST: For the reasons explained above, we, on behalf of our client, request that a decision be made to grant separation, and that the court costs and attorney’s fees be borne by the defendant. …/…/…
Plaintiff’s Attorney
Attorney
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